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DOE O 5480.24, Nuclear Criticality Safety

Functional areas: Environmental Quality & Impact

Canceled by DOE N 251.4 of 9-29-1995.
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Section 1

. \ US. Department; Washington, (lllB of Energy D.C. SUBJECT: NUCLEAR CRITICALITY SAFETY .— ORDER I I I DOE 5480.24 I 8-12-92 1. PURPOSE. To establish nuclear criticality safety program requirements ensuring that: a. Criticality safety is comprehensively addressed and receives an.objective review, with all identifiable risks reduced to acceptably low levels and management authorization of the operation is documented. 2. b. The public, workers, Government property and essential operations are protected from the effects of a criticality incident. WM. The provisions of this Order apply to all Departmental Elements and to covered contractors to the extent implemented under a contract or other agreement. A covered contractor is a seller of supplies or services performing work on-site at a Department of Energy (DOE)-owned or -leased facility and involving significant quantities of fissionable material (excluding that inside the reactor core) on nuclear sites. A covered contract includes procurement contracts and subcontracts. The term “contract” does not include small purchases. This Order does not apply to activities that are regulated through license by the Nuclear Regulatory Commission (NRC) or a NRC agreement State. This Order does Order 12344 and Program. This Order does not apply to those facilities and activities under Executive Public Law 98-525 that comprise the Naval Nuclear Propulsion not apply to activities involving nuclear explosives. 3. POLICY. Fissionable materials shall be produced, processed, stored, transferred, disposed or handled in such a manner that the probability of a criticality incident is acceptably low, and to the extent practical, Government and private personnel and public and private property are protected from damaging effects and undue hazards that may arise from a criticality incident. a —— DISTRIBUTION: INITIATED BY: All Departmental Elements Office of Nuclear Energy , . — . 2 o DOE 5480.24 8-12-92 ‘9 a. b. c. d. e. f. 9“ h. i. J. DOE 1324.2A, RECORDS DISPOSITION, of 9-13-88, which for retention of records and documents. DOE 5000.3A, OCCURRENCE REPORTING AND PROCESSING OF INFORMATION, of 5-30-90, which establishes a system occurrences having programmatic significance. contains procedures OPERATIONS for reporting unusual DOE 5480.18, ENVIRONMENT, SAFETY, AND HEALTH PROGRAM FOR DEPARTMENT OF ENERGY OPERATIONS, of 9-23-86, which sets forth the responsibilities and requirements for an environment, safety, and health (ES&H) program. DOE 5480.3, SAFETY REQUIREMENTS FOR THE PACKAGING AND TRANSPORTATION OF HAZARDOUS MATERIALS, HAZARDOUS SUBSTANCES, AND HAZARDOUS WASTES, of 7-9-85, which describes the requirements for packaging and transportation of hazardous materials, hazardous substances, and hazardous wastes. DOE 5480.4, ENVIRONMENTAL PROTECTION, SAFETY, AND HEALTH PROTECTION STANDARDS, of 5-15-84, which specifies the application to mandatory ES&H standards of DOE operations. DOE 5480.11, RADIATION PROTECTION FOR OCCUPATIONAL WORKERS, of 12-21-88, which establishes DOE’s on-site radiation protection program. DOE 5480.20, PERSONNEL SELECTION, QUALIFICATION, TRAINING AND STAFFING REQUIREMENTS AT DOE REACTOR AND NON-REACTOR NUCLEAR FACILITIES, of 2-20-91, which establishes requirements for selection of personnel, qualification, and training at DOE reactor and non-reactor nuclear facilities. DOE 5480.23, NUCLEAR SAFETY ANALYSIS REPORT, of 4-10-92, which establishes uniform requirements for the preparation and review of safety analyses.

Section 2

DOE 5482.lB, ENVIRONMENT, SAFETY, AND HEALTH APPRAISAL PROGRAM, of 9-23-86, which presents DOE’s policy and requirements for appraisals of programs. DOE 5484.1, ENVIRONMENTAL PROTECTION, SAFETY, AND HEALTH PROTECTION INFORMATION REPORTING REQUIREMENTS, of 2-24-81, which establishes the requirements and procedures for reporting and investigating matters of significance for the protection of environment, safety, and health at DOE operations. .{ 1“ 4% DOE 5480.24 8-12-92 3 k. 1. m. n. o. P. q“ r. s. t. u. v . DOE 5500.2 B.) EMERGENCY CATEGORIES, CLASSES, AND NOTIFICATION AND REPORTING REQUIREMENTS, of 4-30-91, which establishes requirements for the coordination and direction of planning, preparedness, and response to operational emergencies. DOE 5500.3A, PLANNING AND PREPAREDNESS FOR OPERATIONAL EMERGENCIES, of 4-30-91, which establishes requirements for the development of site- specific emergency plans and procedures at nuclear facilities. DOE 5500.4A, PUBLIC AFFAIRS POLICY AND PLANNING REQUIREMENTS FOR EMERGENCIES, of 6-8-92, which establishes requirements for public affairs actions for emergency situations. DOE 5700.6C, QUALITY ASSURANCE, of 8-21-91, which describes DOE’s quality assurance program requirements for nuclear facilities and activities. DOE 6430.lA. GENERAL DESIGN CRITERIA. of 4-6-89. which contains the criteria for the design Code of Federal Regulat Source Material,” which issuance of licenses to Code of Federal Regulat Production and Utilizat governing the licensing and construction of DOE’facilities. ens, Title 10, Part 40, “Domestic establishes procedures and criter- handle source material. ens, Title 10, Part 50, “Domestic L a L on Facilities,” which prescribes cr of production and utilization facil censing of for the censing of teria ties. Code of Federal Regulations, Title 10, Part 60, “Disposal of High-Level Radioactive liastes-in Geological Repositories,fi which regulates-the disposal of high-level radioactive wastes in geological repositories. Code of Federal Regulations, Title 10, Part 70, “Domestic Licensing of Special Nuclear Material,” which establishes requirements for transportation and for preparation of licensed material for shipment. Code of Federal Regulations, Title 10, Part 71, “Packaging and Transportation of Radioactive Material.” DOE 1540.lA, MATERIALS TRANSPORTATION AND TRAFFIC MANAGEMENT, of 7-8-92, which covers the management of materials transportation activities, including traffic management for other than intrabuilding and intrasite transfers. DOE 1540.2, HAZARDOUS MATERIAL PACKAGING FOR TRANSPORT-ADMINISTRATIVE PROCEDURES, of 9-30-86, which establishes the administrative procedures for certification and use of radioactive and other hazardous materials packaging by DOE. 4 5. QWNLLUK. DOE 5480.24 8-12-92 a. b. c. d. e. f. JXitlcal . itv Inc”dent The release of energy as a result of accidentally producing a sel~-sus~aining or divergent neutron chain reaction. FISSIO able . . Materials Nuclides capable of sustaining a neutron-induced fissio~ chain reactio~ (e.g., uranium-233, uranium-235, plutonium-239, plutonium-238, plutonium-241, neptunium-237, americium-241, and curium- 244). -. A source of danger (i. e., material, energy source, or operation) with the potential to cause illness, injury, or death to personnel or damage to a facility or to the environment (without regard for the likelihood or credibility of accident scenarios or consequence mitigation).

Section 3

Nonreactor NUC1 ear Fac il itv. Those activities or operations that involve radioactive and/or fissionable materials in such form and quantity that a nuclear hazard potentially exists to the employees or the general public. Included are activities or operations that: (1) produce, process, or store radioactive liquid or solid waste, fissionable materials, or tritium; (2) conduct separations operations; (3) conduct irradiated materials inspection, fuel fabrication, decontamination, or recovery operations; (4) conduct fuel enrichment operations; or (5) perform environmental remediation or waste management activities involving radioactive materials. Incidental use and generation of radioactive materials in a facility operation (e.g., check and calibration sources, use of radioactive sources in research and experimental and analytical laboratory activities, electron microscopes, and X-ray machines) would not ordinarily require the facility to be included in this definition. Accelerators and reactors and their operations are not included. Nuclear Crltl. . calitv Safetv. The prevention or termination of inadvertent nuclear criticality and protection against injury or damage due to an accidental nuclear criticality. lear Fac ility. Reactor and nonreactor nuclear facilities. DOE 5480.24 8-12-92 9“ h. i. j. k. 1. ml ear ODeration. Processing, storage, transferring, or handling of significant cpantities of fissionable material. Safetv Analvsfi. A documented process: (1) to provide systematic identification of hazards within a given DOE operation; (2) to describe and analyze the adequacy of the measures taken to eliminate, control, or mitigate identified hazards; and (3) to analyze and evaluate potential accidents and their associated risks. Safety Analvsis Rer)ort (SAR~. That report which documents the adequacy of safety analysis for a nuclear facility to ensure that the facility can be constructed, operated, maintained, shut down, and decommissioned safely and in compliance with applicable laws and regulations. $icmificant (IU antitv of Fissionable Material. The minimum mass of fissionable material for which control of at least one parameter is required to ensure subcriticalit.y under all normal and credible abnormal conditions. Jechnical Safety Requirements (TSR~. Those requirements that define the conditions, safe boundaries, and the management or administrative controls necessary to ensure the safe operation of a nuclear facility and to reduce the potential risk to the public and facility workers from uncontrolled releases of radioactive materials or from radiation exposures due to inadvertent criticality. A TSR consists of operating limits, surveillance requirements, administrative controls, use and application instructions, and the bases thereof. (Formerly known as operational silfety requirements for nonreactor nuclear facilities and technical specifications for nuclear reactor facilities.) JemDorary Exerot)tion. A short-term release from a criticality safety requirement. 6. J? ESPONSIBILITIES AND AUTHORITIES. a. The Secretary {S-1) has overall responsibility and authority for the Department’s nuclear facilities and shall take the necessary management actions, through the Deputy Secretary (S-2) or the Under Secretary (S-3), to: (1) Ensure safety of operations, including directing the curtailment and suspension of operations when such operations would result in an undue risk; and (2) Grant permanent exemptions from critical ity safety requirements.

Section 4

.—. ,.. . I 6 DOE 5480.24 8-12-92 b. Jhe Assistant secretary for Nuclear Enerav U!Ul , in addition to the responsibilities prescribed in paragraph 6e below, has overall responsibility for nuclear facility safety policy including nuclear criticality safety policy and specifically shall: (1) (2) (3) (4) (5) Develop, promulgate, and maintain Departmental nuclear safety policy for criticality safety; Develop, promulgate, and maintain guidance materials and provide advice and assistance concerning implementation of nuclear criticality safety policy requirements at nuclear facilities; Provide a central point for coordination within DOE and liaison with other agencies and groups in the development of nuclear facility criticality policy, standards, guidance, and requirements for DOE operations; Review proposed criticality statutes, regulations, standards, and requirements for their application to, and potential impact on, the requirements of this Order; and Concur with-requests for permanent exemptions from critical ity safety requirements. c. Director of the Off Ice of Nuclear Safetv [NS-11. acting as the Department’s independent element responsible for nu~lear safety oversight, has the following responsibilities: (1) (2) (3) (4) Assess and report to the Secretary of Energy on all aspects of nuclear safety related to the implementation’of this Order including the performance of the program offices, DOE Field Offices, and contractors; Review and concur in proposed policy, regulations, standards, and requirements to assess their potential effects on the nuclear safety of DOE facilities; Concur with requests for permanent exemptions from criticality safety requirements; and Develop an enforcement policy and establish an enforcement program consistent with the civil and criminal penalty authority of the Price-Anderson Amendments Act. DOE 5480.24 7 8-12-92 d. The Assistant Secretarv for Environment. Safetv and Health [EH-1), acting as the Department element responsible for radiological protection policy development shall: (1) Develop radiological protection pol icy related to all aspects of this Order. e. Proaram Secretarial Officers (PSOS , shall: (1) (2) (3) (4) (5) (6) (7) (8) (9) Assume primary responsibility for implementation of the DOE nuclear criticality safety program; Provide clear and explicit delegations of responsibility and authority for implementing this Order; Confirm that nuclear criticality safety requirements are identified and provided to the contracting officers for inclusion in contracts; perform reviews, appraisals, and audits at nuclear facilities and field organizations to confirm effective implementation of DOE requirements by program and field organizations. Assure that recommendations made by external and internal oversight groups are addressed in a responsive and timely manner; Transmit the results of the actions taken under subparagraph (4) above to the responsible Head of the Field Organization including any necessary or appropriate instructions as to subsequent action to be taken. Copies of these documents should also be forwarded to NE-1 and NS-l; Confirm, for facilities under their cognizance, that Heads of Field Organizations comply with subparagraph 6f below. The execution of this responsibility should include assurance that recommendations made by other offices are addressed in a responsive and timely manner;

Section 5

Ensure that appropriate nuclear criticality safety requirements are included in long-range program plans, construction, operation, modification, and decommissioning of DOE operations; Obtain special technical assistance, as needed, in the performance of assigned functions when the expertise required is not available in a given office; Take such action as may be appropriate to ensure nuclear criticality safety, including directing the DOE Field Office Manager to curtail I 8 ( lo) (11) (12) (13) (14) (15) (16) DOE 5480.24 8-12-92 and suspend operations when, in the PSO’S opinion, such operation would result in undue risk;” Ensure that documents generated under this OOE Orders are reviewed for classification Grant temr)orary exemptions for criticality Order and other related where appropriate; safety requirements after providing-the secretary notice. Prior to-approval, NS-1 shall also be notified in a timely manner in order to discharge its assigned responsibilities. Request the Secretary grant permanent exemptions from critical ity safety requirements and responsibilities after concurrence from the Assistant Secretary for Nuclear Energy and the Director of the Office of Nuclear Safety; Transmit adequate criticality safety program information in a timely manner to NS-l; Recommend to the Secretary facility restart after shutdown for criticality safety reasons; Approve the determination that the potential for criticality does not exist for activities specified in paragraph 7b below; and Approve in situ subcritical measurements. f. DOE Field Office Manaq rse shal 1: (1) Assume line management responsibility for the criticality safety of assigned nuclear facilities as directed by the PSO; (2) Assure adequate consideration for, and take action on, critical ity safety issues related to protection of environment, safety, and health during siting, design, construction, operation, maintenance, modification, and decommissioning; (3) Review safety analyses including nuclear critical ity safety evaluations and changes thereto consistent with this Order, DOE 5480.23, and other Orders in the DOE 5480 series; (4) Take such action as may be appropriate, including curtailment and suspension of operations, when, in their opinion, such operations may result in an undue risk to health, safety, or the environment; L DOE 5480.24 8 - 1 2 - 9 2 . . . . 9 . - (5) ~;f~~~,i n the review and development of ES&H codes, standards, and. . \ (6) Provide the PSO (copy to NS-1) with independent criticality safety evaluations; (7) Assure t.lhat. DOE contractors to whom this Order is made applicable implement the requirements in paragraph 7 of this Order and provide advisory services to DOE contractors and subcontractors on matters involving policies, standards, codes, guides, and procedures for environmental, safety, and health protection including the requirements of this Order; (8) Provide For an overview of criticality safety; and,- (9) Assure tlhe integration of both criticality safety and materials control and accountability in developing a cost effective criticality safety program.

Section 6

90 Direct or of the Naval Nuclear Propulsion Proaram: Executive Order 12344, statutorily prescribed by P.L. 98-525 (42 U.S.C. 7158, Note) establishes the responsibilities and authority of the Director of the Naval Nuclear Propulsion Program (who is also the Deputy Assistant Secretary for Naval Reactors within the Department) for all facilities and activities that comprise the Program, a joint Navy-DOE organization. These executive and legislative actions establish that the Director is responsible for all matters pertaining to naval nuclear propulsion, including direction and oversight of environment, safety, and health matters for all program facilities and activities. Accordingly, the provisions of this Order do not apply to the Naval Nuclear Propulsion Program. .- . “f “ 10 DOE 5480.24 8-12-92 7. UIREME TsN The contractor criticality safety program for nuclear facilities s~all include the following requirements: a. The basic elements and control parameters of programs for nuclear criticality safety shall satisfy the requirements of the following mandatory American Nuclear Society’s ANSI/ANS nuclear criticality safety standards: ANS-8. 1, “Nuclear Criticality Safety in Operations with Fissionable Materials Outside Reactors,” except paragraphs 4.2.2 and 4.2.3. ANS-8.3 , “Criticality Accident Alarm System,” except paragraphs 4.2 and 4.2.2. ANS-8. 5, “Use of Borosilicate-Glass Raschig Rings as a Neutron Absorber in Solutions of Fissile Material.” ANS-8. 15, “Nuclear Criticality Control of Special Actinide Elements.” ANS-8.19, “Administrative Practices for Nuclear Criticality Safety.” ANS-8 .7, “Guide for Nuclear Criticality Safety in the Storage of Fissile Materials.” (1) Contractors shall be required to comply with the requirements (“shall” statements) and the recommendations (“should” statements) of the mandatory ANS nuclear criticality safety standards except as modified below. When the cognizant PSO approves the technical basis for nonadherence of a recommendation in the ANS standards, the recommendation shall not become a requirement of this Order. Conversely, when the cognizant PSO does not approve nonadherence of a recommendation of the ANS standards, that recommendation shall become a requirement under this Order. (2) For DOE application, the following sections of ANS-8.1, “Nuclear Criticality Safety in Operations with Fissionable Materials Outside Reactors,” shall be read as follows: (a) 4.2 .2 Double Contingency Princit)l~. Process designs shall incorporate sufficient factors of safety to require at least two unlikely, independent, and concurrent changes in process conditions before a criticality accident is possible. Protection shall be provided by either (a) the control of two independent process parameters (which is the preferred DOE 5480.24 8-12-92 (t)) aplproach, if practical) or (b) a system of multiple (at least two) controls on a single parameter. In all cases, no single failure shall result in the potential for a criticality accident. The basis for selecting either approach shall be fully documented.

Section 7

U*3 Geome ry Controlt As a first priority, reliance Shall be placed on equipment design in which dimensions of the contained fissionable material and spacing between equipment are limited via passive engineering controls. Where geometry control is not feasible, the preferred order of controls is other passive engineering controls, active engineering controls, and administrative controls. Feasibility is determined by weighing risk versus practicality/cost. Full advantage may be taken of any nuclear characteristics of the process materials and equipment. All dimensions, nuclear properties, and other features upon which rel lance is placed shall be verified prior to beginning operations, and control shall be exercised to maintain them. The basis for not selecting geometry control shall be fully documented. b. The requirements in ANSI/ANS-8.3 relating to the needs for an alarm system are not applicable to this Order. For the purpose of this Order, Criticality Alarm Systems (CAS) and criticality detection systems shall be required as follows: (1) (2) In those cases where the mass of fissionable material exceeds the 1 imits mtablished in paragraph 4.2.1 of APJSI/#NS-8.3 and the probability of criticality is greater than 10- per year (as documented in a DOE approved SAR), a CAS meeting ANSI/ANS-8.3 shall be provided to cover occupied areas in which the expected dose exceeds 12 Rads in free air, where a CAS is defined to include a criticality accident detection device and a personnel evacuation alarm. In thosp cases where the mass of fissionable material exceeds the 1 imits [established in paragraph 4.2.1 of ANSI/#NS-8.3 and the probability of criticality is greater than 10- per year, (as documented in a DOE approved SAR), but there are no occupied areas in which the expected dose exceeds 12 Rads in free air, a criticality detection system shall be provided where a criticality detection system is defined to be an appropriate criticality accident detection device but without an immediate evacuation alarm. The criticality accident detection system response time should be sufficient to allow for appropriate process-related mitigation and recovery actions. While an immediate evacuation alarm is not required under these circumstances, evacuation shall be implemented . . . ., . . . . ,,.. “..,.. . : .“ . . DOE 5480.24 8-12-92 . (3) (i.e. evacuation notification or delayed alarm) if potential doses to occupational workers could be effectively limited by such actions in accordance with DOE 5480.11. In those cases where the mass of fissionable material exceeds the limits established in paragraph 4.2.1 of ANSI/ANS-8.3, but a criticality accident is determined to be impossible due to the physical form of the fissionable material, or the Probability of occurrence is determined to be less than 10- per year (as documented in a DOE approved SAR), neither a CAS nor a criticality detection system is required. In addition, neither a CAS nor a criticality detection system is required to be installed underwater when fissionable material is handled or stored beneath water shielding that is adequate to protect personnel; however a means to detect fission product gasses or other volatile fission products should be provided in occupied areas immediately adjacent to such underwater storage areas except for fuel systems where no fission products are likely to be released. Also, neither a CAS nor a criticality detection system are required for fissionable material during shipment of fissionable material packaged in approved shipping containers, or fissionable material packaged in approved shipping containers awaiting transport provided no other operation involving fissionable material not so packaged is permitted on the dock or in the shipment area.

Section 8

(4) The decision to install a criticality detection system rather than a CAS, and the decision that neither a CAS nor a criticality detection system is necessary, must be justified based upon a documented DOE approved Safety Analysis. c. Nuclear criticality safety programs shall be fully documented. In addition to the requirements of the ANS standards, contractors shall perform detailed nuclear criticality safety analyses for specific operations, storage arrangements, and the handling and transportation of fissionable materials. The basis for criticality safety shall be included in the facility SAR. Additionally, the limiting conditions of operation for criticality safety shall be included in the facility TSRS. Values presented in the standards to ensure criticality safety should be used cautiously and should include all adjustments, conditions, and ranges of applicability called for by the mandatory standards in paragraph 7a of this Order. The Critical ity Safety section of the SAR shall include (or be included by referring to other sections of the SAR) but not be limited to the following: I I J’ Cl} DOE 5480.24 8-12-92 (1) A description, using appropriate sketches or drawings, of equipment and facilities in which the hazard of criticality exists showing dimensions in sufficient detail to permit evaluation of the information mentioned in subparagraphs 7c(3) through 7c(6) below. (2) A statement of the chemical and physical form of fissionable material in each step of the process, including isotopic content, the nature of any material, and the resulting concentrations, densities, and degrees of moderation throughout the steps of the process, (3) A statement of the maximum quantities of fissionable material at any one tim~ in each step of the process, including a description of the technical practices which are intended to prevent exceeding these maximum quantities. (4) A description of the methods of collection, handling, and transportation products from each process area or individual operation and evaluation of the nuclear safety of these methods, (5) An analysis of criticality incident scenarios and their impact on health and safety of the workers and/or public. This analysis will be used to determine the conditions of operation for criticality safety, the design of the CAS as noted in subparagraph (7) below, and the need for audible and/or visual alarms. (6) A description of the safety control parameters which are intended to prevent criticality resulting from events such as: accumulation of fissionable material in scrap or waste, lathe turnings, crucible slag, pickling solutions, choppings, sumps, filters, etc. Also included shall be the description of the technical practices used to prevent exceeding the safety control parameters. (7) A descrllption of the installed CAS and emergency procedures, including alarm levels, fail-safe features, response time of devices, and frequency of evacuation drills. Pertinent documents shall show the location of all detectors, their distance to possible sources of criticality, and intervening shielding and audio and visual alarms. (8) A description of the technical practices and measurement control program (including reliability and operability characteristics) used in determining the quantities of fissionable material (or other materials such as soluble poisons to prevent accidental criticality) present in any location and the uncertainties of the measured .,.. 14 DOE 5480.24 8-12-92

Section 9

‘ f 8. d. e. f. values. The measurement control program shall be in accordance with the latest edition of DOE 5700.6C, QUALITY ASSURANCE. (9) An analysis of the spacing of masses of fissionable material within each process area and separation from fissionable material in adjoining areas. Contractors shall establish”a monitoring and surveillance program to prevent accumulations of fissionable materials in, but not limited to, process equipment and storage, pipe, and ventilation systems. If unsafe accumulations are detected, corrective measures shall be taken to prevent criticality hazards. Transportation and Storage Requirements for Fissionable Material. (1) The requirements of this Order shall apply to all activities where fissionable material is transferred from one operation to another within a facility and from one on-site location to another. (2) For on-site transportation, contractors shall be required to follow the guidelines of an approved on-site transportation safety manual. (3) The requirements of DOE 5480.3 shall be complied with regarding off- site shipment of fissionable material. (4) DOE 5610.1 shall apply for the safe transportation of weapon components and special assemblies shipped in national defense. (5) Fissionable materials shall be defined as either “in process” or ‘not in process” for facilities that involve both processes and storage. Fissionable material not in process shall be properly stored. Guidelines for Fire Fighting (1) Contractors shall establish guidelines for permitting fire fighting water or other moderating materials used to suppress fires within or adjacent to moderation controlled areas. These guidelines shall be based on comparisons of risk and consequences of accidental criticality with the risks and consequences of postulated fires for the respective area(s). The basis for the guidelines shall be fully documented in a DOE approved Safety Analysis. ~NTATION PLAN. Contractors shall submit a plan armroval to imr)lement the requirements of this Order. Implementation-plan shall occur within this Order. 180 days after to the Lead PSO for Submittal of the the date of issuance of @&r.lu*s*N.vy(Retir~)D. WATKINS

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