ML20217P780
| ML20217P780 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/03/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20217P768 | List: |
| References | |
| 50-293-98-03, 50-293-98-3, NUDOCS 9804100192 | |
| Download: ML20217P780 (12) | |
See also: IR 05000293/1998003
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No:
_50-293
License No:
Report No:
50-293/98-03
Licensee:
Boston Edison Company (BECo)
Facility:
Pilgrim Nuclear P-ower Station, Unit #1
^ Location:
Plymouth, Massachusetts
Dates:
March 2-5 and 11-12,1998
Inspectors:
Edward B. King, Physical Security inspector
Paul R. Frechette, Physical Security inspector
Approved by:
Michael C. Modes, Chief
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Emergency Preparedness & Safeguards Branch
Division of Reactor Safety
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9804100192 990403
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EXECUTIVE SUMMARY
Pilgrim Nuclear Power Station
NRC Inspection Report No. 50-293/98-03
In general, the licensee maintained an effective security program.' However, the inspectors
determined that multiple examples of equipment failures associated with the protected area
assessment system existed. Assessment aid concerns were identified in the licensee's
1996 and 1997 quality assurance (QA) audits as well as in the 1995-1997 NRC security
inspection reports.' The failure to address known programmatic weaknesses is a concern.
The 1996 and 1997 security, access authorization, and FFD audits were thorough and in-
depth, alarm station operators were knowledgeable of their duties and responsibilities, and
communication requirements were being performed in accordance with the NRC-approved
physical security plan (the Plan). Personnel search equipment was being tested and
maintained in accordance with licensee procedures and the Plan, personnel and packages
were being properly searched prior to protected area (PA) access and controls were in
place, which included a departmental self-assessment program, for identifying, resolving,
and preventing programmatic problems.
l Security training was being performed in accordance with the NRC-approved training and
qualification (T&O) plan. However, the inspectors noted that the licensee has not
conducted drills associated with tactical response training for over 18 months. Based on
- discussions with security training staff, the licensee was the process of re-evaluating
target sets and time lines to enhance their tactical response capabilities. Additionally, the
- training department was in the process of re-evaluating the licensee's defensive strategy
associated with protecting the facility against the design basis threat as described in
10CFR 73.1. The licensee planned to begin conducting tactical response drills using the
new target sets and defensive strategies in the near future in preparation for the '
Operational Safeguards Response Evaluation (OSRE) scheduled for the week of June 1,
1998.
- As an enhancement to the inspection, the UFSAR initiative, Section 4.5 of the Plan, titled
" Keys, Locks, and Combinations" was reviewed. The inspectors determined, by physical
verification, discussions with security supervision, and procedural reviews, that locks and
keys were being maintained as required in the Plan.
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Report Details
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Conduct of Security and Safeguards Activities
a.
Inspection Scone (81700)
Determine whether the conduct of security and safeguards activities met the
licensee's commitments in the NRC-approved security plan (the Plan) and NRC
regulatory requirements. The security program was inspected during the period of
March 2-5 and 11-12,1998. Areas inspected included: access authorization
program; alarm stations; communications; protected area access control of
personnel and packages.
b.
Observations and Findinos
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Access Authorization Proaram. The inspectors reviewed implementation of the
Access Authorization (AA) program to verify implementation was in accordance
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with applicable regulatory requirements and Plan commitments. The review
included an evaluation of the effectiveness of the AA procedures, as implemented,
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and an examination of AA records for 10 individuals. Records reviewed included
both persons who had been granted and had been denied access. The AA program,
as implemented, provided assurance that persons granted unescorted access did not
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constitute an unreasonable risk to the health and safety of the public. Additionally,
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the inspectors verified by reviewing access denial records and applicable
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procedures, that appropriate actions were taken when individuals were denied
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access or had their access terminated which included a formalized process that
allowed the individuals the right to appeal the licensee's decision.
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Alarm Stations. The inspectors observed operations of the Central Alarm Station
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(CAS) and the Secondary Alarm Station (SAS) and verified that the alarm stations
were equipped with appropriate alarms and communications capabilities. However,
as noted in Sect 6;: S2 of this report, multiple examples of equipment failures
associated with We assessment program existed which preciudad the alarm station
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operators ability to assess the cause of an alarm. Interviews with the alarm station
operators found them knowledgeable of their duties and responsibilities. The
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inspectors also_ verified, through observations and interviews, that the alarm
stations were continuously manned, independent and diverse so that no single act
could remove the plants capability for detecting a threat and calling for assistance
and the alarm stations did not contain any operational activities that could interfere
with the execution of the detection, assessment and response functions.
Communications. The inspectors verified, by document' reviews and discussions
with alarm station operators, that the alarm stations were capable of maintaining
continuous intercommunications, communications with each security force member
(SFM) on duty, and were exercising communication methods with the local law
enforcement agencies as commi'.ted to in the Plan.
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Protected Area (PA) Access Control of Personnel and Hand-Carried Packaaes.
On March 3 and 4,1998, the inspectors observed personnel and package search
activities at the personnel access portal.11e inspectors determined, by
observations, that positive controls were in pl ace to ensure only authorized
individuals were granted access to the PA and that all personnel and hand carried
items entering the PA were properly seamhed. However, on March 4,1998, at
0710 Hours, an individual gained a<, cess into the protected area with an incorrect
identification badge. This occurred when a SFM enrolled an individual, that was
having difficulty with their identification badge at the protected area turnstyle, into
the hand geometry system without verifying that the individual had the correct
identification badge. The inspectors discussed the event with security management
and determined that the event occurred due to the SFM's inattention to detail. The
inspectors reviewed the licensee's corrective actions and determined that the event
was isolated and not indicative of a decline in programmatic performance.
c.
Conclusions
The licensue was conducting its security and safeguards activities in a manner that
protected public health and safety and that this portion of the program, as
implemented, met the licensee's commitments and NRC requirements.
S2
Status of Security Facilities and Equipment
a.
Inspection Scope (81700)
Areas inspected were: Testing, maintenance and compensatory measures; PA
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assessment aids; and personnel search equipment.
b.
Observations and Findinas
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Testina, Maintenance and Comoensatorv Measures. The inspectors reviewed
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testing and maintenance records for security-related equipment and found that
documentation was on file to demonstrate that the licensee was testing and, with
the exception of the assessment aids, maintaining systems and equipment as
committed to in the Plan. A priority status was being assigned to each maintenance
r3 quest and repairs were normally being completed within the same day a
maintenance request necessitating compensatory measures was generated. The
inspectors reviewed security event logs and maintenance work requests generated
over the past six months. These records indicated that the need for establishing
compensatory measures due to equipment failures was minimal and when
implemented, the compensatory measures did not reduce the effectiveness of the
security systems as they existed prior to the failure.
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However, the ' inspectors also noted that maintenance requests that were classified
with a low priority status would remain open for an extended period of time.
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Specifically, requests associated with assessment aids, not requiring compensatory
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measures, would either remain open for extended periods or the requests were
reissued under a new maintenance request number and placed back into the tracking
system. This resulted in the assessment aids not receiving the necessary level of
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management attention due to the low priority status of the work requests and
management's failure to redirect the work efforts of the maintenance and l&C
groups.
Assessment Aids. On March 4,1998, the inspectors evaluated the effectiveness of
the assessment aids, by observing on closed circuit television (CCTV), a SFM
conducting a walkdown of the PA. The inspectors determined that multiple
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examples of equipment failures associated with the assessment program existed.
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RiiS PARAGRAPH CONTAINSSAFEGUARDS
INFORMATION ANDIS NOTFOR PUBUC
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DISCl0SUREITISINTENTIONALLY
LEFT BLANK.
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' " Assessment aid concerns were identified in the 1996 and
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1997 licensee's quality assurance (QA ) security audits as well as in the 1995-1997
NRC security inspection reports. The failure to address known programmatic
weaknesses is a concern. The licensee took immediate action to implement
compensatory measures for the degraded assessment system when it was identified
during this inspection. The licensee failure to maintain the protected area
assessment aids as required in the NRC-approved Plan is an apparent violation of
NRC requiremonts. (eel 50-293/98-03-01)
Personnel and Packaae Search Eauioment. The inspectors observed both the routine
use and the daily performance testing of the licensee's personnel and package
search equipment. The inspectors determined, by observations and procedural
reviews, that the search equipment performs in accordance with licensee
procedures and Plan commitments.
c.
Conclusions
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The licensee's security facilities and equipment were determined, with the exception
of the assessment aid concerns, to be well maintained and reliable and were able to
meet the licensee's commitments and NRC requirements.
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Security and _ Safeguards Procedures and Documentation
a.
Insoection Scoce (81700)
Areas inspected were: implementing procedures and security event logs.
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b.
Observations and Findinas
Security Proaram Procedures. The inspectors verified that the procedures were
consistent with the Plan commitments, and were properly implemented. The
verification was accomplished by reviewing selected implementing procedures
associated with PA access control of personnel and packages and testing and
maintenance of personnel search equipment.
Security Event Loas. The inspectors reviewed the Security Event Log for the
previous eight months. . Based on this review, and discussion with security
management, it was determined that the licensee appropriately analyzed, tracked,
resolved and documented safeguards events that the licensee determined did not
require a report to the NRC within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
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c.
Conclusions
Security and safeguards procedures and documentation were being properly
implemented. Event Logs were being properly maintained and effectively used to
analyze, track, and resolve 'feguards events.
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Security and Safeguards Staff Knowledge and Performance
a.
Inspection Scone (81700)
Area inspected was security staff requisite knowledge.
b.
Observations and Findings
Security Force Reauisite Knowledae. The inspectors observed a number cf SFM's
in the performance of their routine duties. These observations included alarm
station operations, personnel and package searches, and performance testing of the
personnel search equipment. Additionally, the inspectors interviewed SFMs and
based on the responses to the inspectors' questioning, determined that the SFMs -
were knowledgeable of their responsibilities and duties, and could effectively carry
out their assignments.
c.
[ansjydgnt
' The SFMs adequately demonstrated that they have the requisite knowledge
necessary to effectively implement the duties and responsibilities associated with
their position.
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Security and Safeguards Staff Training and Qualifications (T&O)
a.
Insoection Scape (81700)
Areas inspected were security training and qualifications and training records,
b.
Observations and Findinas
- Security Tr:4.no and Qualifications. On March 3,1998, the inspectors randomly
selected and reviewed T&Q records of 7 SFMs. Physical and requalification records
were inspected for armed supervisory and non-supervisory personnel. The results
of the review indicated that the security force was being trained in accordance with
the approved T&Q plan. Thi inspectors held discussions with the security training
staff, and was informed that the security training department has not conducted
drills associated w!th tacGcal response training for over 18 months. However,
security with the support of plant operations, was in the process of re-evaluating
target sets and time lines to enhance their tactical response capabilities. The
licensee planned to begin conducting tactical response drills using the new target
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sets and defensive strategies in the near future in preparation for the Operational
Safeguards Response Evaluation (OSRE) scheduled for the week of June 1,1998.
Trainina Records. The inspectors were able to verify, by reviewing training records,
that the records were properly maintained, accurate and reflected the current
qualifications of the SFMs.
c.
Conclusions
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Security force personnel were being trained in accordance with the requirements of
the Plan. Training documentation was properly maintained and accurate and the
training provided by the training staff was effective.
S6
Security Organization and Administration
a.
Inspection Scope (81700)
Areas inspected were management support, management effectiveness and staffing
' levels,
b.
Observations and Findinas
Manaaement Suonort. The inspectors reviewed various program enhancements
made since the last program inspection, which was conducted in August 1997.
These enhancements included the procurement of new base station radios for
- enhanced communications in the alarm ctations and new weapons and equipment
. to enhance tactical response capabilities and improve tactical training.
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Manaaement Effectiveness. The inspectors reviewed the management
organizational structure and reporting chain. The Protective Services Department
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Manager's position in the organizational structure provides a means for making
senior management aware of programmatic needs. However, the inspectors
questioned the involvement of senior management concerning the actions taken to
address long standing protected area assessment aid concerns.
Staffina Levels. The inspectors verified that the total number of trained SFMs
immediately nailable on shift meets the requirements specified in the Plan.
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Conclusions. The level of management support, in general, was adequate to ensure
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effective implementation of the security program, and was evidenced by adequate
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staffing levels and the allocations of resources to support programmatic needs.
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Quality Assurance in Security and Safeguards Activities
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Insoection Scone (81700)
Areas inspected were: audits, problem analyses, corrective actions and
effectiveness of management controls.
b.
Observations and Findinas
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Audits. The inspectors reviewed the 1996 QA audit of the access authorization
- (AA) program, conducted December 18 - 31,1996, (Audit No. 96-12), the 1996
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combined QA audit of the security and fitness-for-duty (FFD) programs, conducted
February 26 - March 15,1996,(Audit No. 96-02), the 1997 QA audit of the FFD
program, conducted February 24 - 28,1997, (Audit No. 97-01), and the 1997 QA
audit of the security program, conducted March 3 - 14,1997, (Audit 97-02). The
audits were found to have been conducted in accordance with the Plan and FFD
rule. To enhance'the effectiveness of the audits, all of audit teams included an
independent technical specialist.
The 1996 AA audit report identified no deficiency reports (DR) and one
recommendation.. The 1996 combined security and FFD audit report identified one
DR and five recommendations associated with the security program and two DRs
associated with the FFD program. The security DR was associated with l&C and
maintenance's failure to meet procedural requirements for processing security
related maintenance requests. The FFD DRs were associated with the software
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developed to randomly select individuals for FFD testing and for the failure to
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. implement corrective actions (procedural guidance) in a timely manner for
- establishing a process to control non-safety related computer applications. The
1997 FFD audit report identified four DRs, one problem report, and two
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recommendations. The DRs were associated with the lack of procedural guidance
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for the use of the computerized random FFD selection process, failure to generate a
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FFD self-assessment plan, failure to submit the required number of blind specimens
to the laboratory for the bst quarter of 1996, and failure to perform an audit of the
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Health and Human Service. (MHS) certified laboratory used by the licensee. The
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' 1997 security audit report identified four DRs and four recommendations. The DRs
were associated with long term record storage, opened security work orders
associated with malfur'ctioning door keepers, inconsistent alarm response by SFMs
in accordance with the Plan, and the licensee's failure to update the security
procedure associated with the hand _ geometry units. The inspectors determined that
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the findings were not indicative of programmatic weaknesses, and the findings
would enhance program effectiveness. Inspectors' discussions with security
management and FFD staff revealed that the responses to the findings were
completed, and the corrective actions were effective.
Problem Analyses. The inspectors reviewed data derived from the security
department's self-assessment program. Potential weaknesses were being properly
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identified, tracked, and trended.
Corrective Actions. The inspectors reviewed corrective actions implemented by the
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- licensee in response to the QA audit and self-assessment programs. The corrective
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actions were effective, evidence by a reduction in personnel performance issues and
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loggable safeguards events.
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Effectiveness of Manaaement Controls. The inspectors verified, by documentation
reviews, that the licensee has programs in place for identifying, analyzing and
resolving problems. They include the performance of annual QA audits, a
departmental self-assessment program and the use of industry data such as
- violations of regulatory requirements identified by the NRC at other facilities, as a
criterion for self-assessment.
c.
Conclusions
The review of the licensee's Audit program indicated that the audits were
comprehensive in scope and depth, that the audit findings were reported to the
appropriate level of management, and that the program was being properly
administered. In addition, a review of the documentation applicable to the self-
assessment program indicated that the program was effectively implemented to
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identify and resolve potential weakness.
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Exit Meeting Summary
The inspector met with licensee representatives at the conclusion of the inspection on
March 12,1998. At that time, the purpose and scope of the inspection were reviewed,
and the preliminary findings were presented. The licensee acknowledged the preliminary
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inspection findings.
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Review of Updated Final Safety Analysis Report (UFSAR)
A recent discovery of a licensee operating its facility in a manner contrary to the UFSAR
description highlighted the need for a special focused review that compares plant practices,
procedures, and parameters to the UFSAR description. Since the UFSAR does not
specifically include security program requirements, the inspectors compared licensee
activities to the NRC-approved physical security plan, which is the applicable document.
While performing the inspection discussed in this report, the inspectors reviewed Section
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4.5 of the Plan,' titled " Keys, Locks, and Combinations". The inspectors determined, by
interviews with security force members (SFMs), observations, and procedural reviews, that
' visitor access was being controlled and maintained as required in the Plan,
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PARTIAL LIST OF PERSONNEL CONTACTED
Licensee
L.J. Olivier, Vice President Nuclear
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C.S. Goodard, Plant Manager
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C.H. Minott, Project Manager
J. Neal, Protection Services Department Manager
N. Desmond, Regulatory Relations Manager
M.T. Lenhart, Senior Regulatory Engineer
J.L.Taomina, Instrumentation and Control Department Manager
E. Neary, Security Operations Supervisor
W. Riggs, Nuclear Services Group Manager
T. Campbell, Security Services Supervisor
J. Keene, Regulatory Affairs Manager
Contractor
R. Wheat, Project Manager, Protection Technology incorporated (PTI)
N. Metcalf, Operations Manager, PTl
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Nuclear Reaulatory Commission - Reaion i
R. Laura, Senior Resident inspector
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R. Arrighi, Resident inspector
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INSPECTION PROCEDURES USED
IP 81700:
Physical Security Program for Power Reactors
LIST OF ACRONYMS USED
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SFM
security force member
quality assurance
the Plan
NRC-approved physical security plan
protected area
T&Q
training and qualification
central alarm system
secondary alarm system
Updated Final Safety Analysis Report
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DR
deficiency report
closed circuit television
Health and Human Services
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