Bruce D. Foster, Ralph G. Musick, James P. Pedalino, and Janet L. Cowley
Bechtel Nevada Corporation

Cathy C. Karney
DOE/NV

John L. Kremer
NFS-RPS

This paper describes design and construction, project management, and testing results associated with the Waste Examination Facility (WEF) recently constructed at the Nevada Test Site (NTS). The WEF and associated systems were designed, procured, and constructed on an extremely tight budget and within a fast-track schedule. Part I of this paper focuses on design and construction activities, Part II discusses project management of WEF design and construction activities, and Part III describes the results of the transuranic (TRU) waste examination pilot project conducted at the WEF. In Part I, the waste examination process is described within the context of Waste Isolation Pilot Plant (WIPP) characterization requirements. Design criteria are described from operational and radiological protection considerations. The WEF engineered systems are described. These systems include isolation barriers using a glove box and secondary containment structure, high-efficiency particulate air (HEPA) filtration and ventilation systems, differential pressure monitoring systems, and fire protection systems. In Part II, the project management techniques used for ensuring that stringent cost/schedule requirements were met are described. The critical attributes of these management systems are described with an emphasis on team work. In Part III, the results of a pilot project directed at performing intrusive characterization (i.e., examination) of TRU waste at the WEF are described. Project activities included cold and hot operations. Cold operations included operator training, facility systems walk-down, and operational procedures validation. Hot operations included working with plutonium-contaminated TRU waste and consisted of waste container breaching, waste examination, waste segregation, data collection, and waste repackaging.

The Waste Examination Facility (WEF) performs a critical function in the Nevada Test Site (NTS) strategy for characterizing and certifying transuranic (TRU) waste for disposal at the Waste Isolation Pilot Plant (WIPP) in Carlsbad, New Mexico. Definitive design and construction of the WEF was completed within a nine-month period from October 1996 through June 1997. Construction costs were approximately $1.96 million. Installed equipment for specific short-term operational considerations raised the cost to approximately $2.3 million. This paper describes the design, construction, and operational considerations that went into completing the WEF on time and under budget and is presented in three parts: Part I describes the facility design, including design criteria and engineered systems; Part II discusses the project management techniques applied to facility design, construction, and subcontractor work to ensure that cost and schedule constraints were met; and Part III presents the results of a pilot project which utilized the WEF for examining TRU waste.

Approximately 590 cubic meters (20,825 cubic feet ) of TRU waste are stored at the NTS in drums and waste boxes, with the bulk of these containers consisting of 208-liter (55-gallon) drums stored in 322-liter (85-gallon) overpack drums. Waste stored in these containers consists primarily of laboratory debris wastes including some items that are prohibited for shipment to WIPP. These prohibited items must be removed from the waste stream before the waste can be characterized, certified, and disposed at WIPP. Characterization and certification requirements include the following elements:

• Waste examination (by intrusive or nondestructive means)
• Radioassay
• Headspace gas sampling
• Sampling of homogeneous solids

The WEF was conceptualized to provide an intrusive waste examination and repackaging capability for drums. It is anticipated that approximately 20 percent of the total TRU waste volume will be processed through the WEF. The other required characterization elements (i.e., radioassay, nondestructive examination, and sampling/analysis) are being provided through mobile technologies offered by off-site vendors. These mobile technologies are scheduled to be on site during the March 1998 time frame. Therefore, only waste examination and repackaging are addressed here.

To meet NTS waste examination and repackaging needs, the WEF had to be designed to provide a means to accomplish the following:

• Staging waste drums designated for examination and repackaging.
• Storing new 208-liter (55-gallon) drums to be used as payload containers during the repackaging process.
• Removing 208-liter (55-gallon) drums from 322-liter (85-gallon) overpack containers.
• Removing lids from 208-liter (55-gallon) waste drums.
• Removing debris waste from waste containers.
• Examining debris waste including breaching confinement layers.
• Documenting waste material parameters in the debris waste stream through a computerized data entry process.
• Weighing waste units.
• Communicating waste material parameter information for data entry.
• Repackaging waste into U.S. Department of Transportation (DOT)-compliant payload containers.
• Videotaping the repackaging process.
• Staging of repackaged payload containers.

In addition to meeting operational requirements described above, the WEF had to be designed to provide radiological protection to operators. TRU waste stored at the NTS is classified as "contact handled," which means that radiation dose rates on contact with the outside of the waste container are less than 200 millirems per hour. Contact-handled waste can be readily manipulated using ALARA-based (As Low As Reasonably Achievable) administrative controls as long as the waste containers are not breached. Therefore, the WEF did not have to be designed to address protection of operators from penetrating radiation. However, once a waste container is breached, the primary hazard is exposure to alpha radiation. Alpha particles pose an internal exposure risk through inhalation as the primary pathway. Because the WEF is used to breach waste containers, it had to be designed to protect workers from inhaling alpha particles. Plutonium is the main radiological constituent. In addition to being an alpha emitter, plutonium is highly toxic and extremely mobile when present as fines (powder-like material). As a result, engineering controls had to focus on systems for isolating the plutonium-contaminated waste form from workers.

NTS TRU waste has been identified as mixed TRU waste based on existing process knowledge data. Consequently, this waste is regulated by the state of Nevada and must be managed in accordance with the Nevada Site Treatment Plan (STP), a U.S. Department of Energy (DOE) document that has been reviewed by the state. STP milestones have subsequently been turned into binding commitments through a Consent Order issued by the state under the Federal Facilities Compliance Act in March 1996. The Consent Order stipulated that the WEF had to be completed and ready to operate by June 30, 1997. This requirement, and the culmination of conceptual design in September 1996, meant that design of the WEF facility and its containment systems, as well as procurement and construction, had to be completed in less than nine months. Failure to meet the June 30 milestone would subject DOE to a schedule of state-imposed fines. Potentially, these fines could be levied on a weekly basis until the facility was completed. This tight schedule necessitated a facility design and construction approach which emphasized simplification, off-the-shelf solutions, and team work.

The NTS TRU waste inventory is currently stored at the Radioactive Waste Management Site (RWMS) located in Area 5 of the NTS (see Figure 1). To minimize handling and drum transportation problems, the decision was made to locate the WEF adjacent to the RWMS. An existing, abandoned building from another NTS site was identified for use as the shell housing WEF operations. This helped minimize overall facility construction costs, although the structure had to be transported to the WEF site. Also, WEF examination and repackaging systems had to fit within the existing building footprint.

The WEF is a 242-square-meter (m²) (2,600-square-foot [ft²]) pre-engineered metal building structure, originally erected at the NTS in 1966 and relocated to the Area 5 RWMS in 1997 (see Figure 2). The 28-m² (300-ft²) HEPA annex, which houses both the 85 cubic meter (m³) (3,000 cubic feet) per minute (CFM) and 28-m³ per minute (1,000-CFM) blowers, is constructed of structural steel columns and metal siding. A 152-millimeter (6-inch) concrete containment curb is constructed around the entire perimeter of the concrete floor slab. All interior concrete surfaces are epoxy-coated for ease of decontamination if necessary. Heating, ventilating, and air conditioning for the building shell are provided by conventional heat pumps and air handlers in a "split" system design. Power for the entire facility including containment system ventilation is 120/208 VAC and is fed from a transformer bank on an existing 34.5 KV overhead power line. A wet-pipe sprinkler system is installed in the WEF building shell, control room, corridors, and other general usage space. However, in the secondary containment structure, fire protection is provided by an on/off, pre-action system. This reduces the chances of inadvertent sprinkler discharge and limits water deluge to necessary quantities, only in case of a fire. Fire detectors are installed throughout the WEF, and alarms are annunciated in work areas, in the control room, and at the NTS fire station in Mercury. The primary containment system glove box is fire protected by a CO₂ system. A floor plan drawing of the WEF is shown in Figure 3. WEF design criteria were formulated based on operational requirements. Specific design criteria, as applicable to operations, are described below.

Because NTS TRU waste is classified as mixed, waste drums awaiting examination and repackaging had to be staged on a curbed Resource Conservation and Recovery Act (RCRA)-compliant pad designated as a 90-day storage pad. This covered and fenced pad, shown in Figure 4, is also used to stage drums that have been repackaged in the WEF as well as for storing empty 322-liter (85-gallon) overpack containers. The pad surface is coated with epoxy to mitigate the potential for liquids to escape to the surrounding environment.

Storage must be provided for empty DOT-compliant payload containers that are used in the repackaging operation. This storage capability is provided on a concrete pad located adjacent to the waste drum staging pad. Additional storage is provided in SeaLand^® containers.

TRU waste to be examined and repackaged is contained in 208-liter (55-gallon) drums inside 322-liter (85-gallon) overpack containers. (The 322-liter [85-gallon] overpack containers were used to provide environmental protection when the waste drums were stored outside.) To examine the contents of the 208-liter (55-gallon) drum, it had to first be removed from the 322-liter (85-gallon) overpack. For this purpose, an overhead crane assembly was installed within the secondary containment structure. Removal of the 208-liter (55-gallon) drums from the overpack was accomplished by first taking the 322-liter (85-gallon) drum lid off underneath a portable HEPA ventilation hood. The hood was required in case the 208-liter (55-gallon) drum was breached and alpha contamination was present. Once the 322-liter (85-gallon) drum lid was removed, the 208-liter (55-gallon) waste drum was lifted from the overpack using the jib crane. The waste drum was then swung to the examination and repackaging location where it was disconnected from the crane hoist mechanism.

Potential contamination hazards associated with this operation necessitate ventilation controls and spill protection. Therefore, the overpack removal operation had to be performed in a location minimizing potential for radiological contamination in the work area. This requirement was met by specifying that work be performed within a HEPA-ventilated secondary containment enclosure operating at relative negative pressure. A negative pressure differential of 2.5 millimeters to 5.0 millimeters (0.1 to 0.2 inches) of water was established such that air flow was from the outside to the inside of the secondary containment enclosure; i.e., least contaminated to most contaminated. Figure 5 shows the containment enclosure.

Negative pressure was maintained through a HEPA ventilation unit operating at 85 cubic meters per minute (3,000 CFM), which is shown in Figure 6. Spill containment was provided by sealing the concrete work area surface with an epoxy coating and enclosing the entire work area within a curb.

Breaching the 208-liter (55-gallon) waste containers required operator isolation from waste container contents to eliminate any potential of exposure to alpha particles. Isolation was accomplished through the use of a glove box. The glove box was maintained at a differential pressure of 19 millimeters (0.75 inches) of water relative to the work area. Negative pressure was provided and maintained by a 28-cubic-meter (1,000-CFM) HEPA unit.

Breaching operations were initiated by attaching the waste drum to a drum manipulator capable of supporting 454 kilograms (1,000 pounds). The drum manipulator (see Figure 5) raises the drum, positions it horizontally, and inserts the top portion into the drum input ring located at the end of the glove box. The top of the drum is sealed inside the glove box using industry standard bag-in techniques. Figure 7 shows the glove box.

Drum lids were removed inside the glove box. An air impact wrench was used to assist in lid removal. Some of the drum lids were glued shut in addition to the standard ring-bolt assembly closure. An air hammer and chisels were used to dislodge the lids in cases where they were glued shut. Once removed, the lid was set aside and the drum contents were ready to be examined.

Debris waste was removed from the waste container by waste handlers working through gloves attached to the glove box. The gloves provided an air-tight seal to isolate waste handlers from the waste and were located on both sides of the glove box. Waste was removed from the waste container one parcel at a time. Waste parcels were made up of individual containers or waste items inside the drum and are termed waste units. The contents of individual waste units must be described in terms of waste material parameters predefined by WIPP. These are shown in Table I. Waste handlers identified the applicable waste material parameter(s) associated with a given waste unit and communicated this information using cordless headsets to the waste control operator. A waste control operator located in the control room outside the containment area recorded the waste material parameter information in the TRU waste characterization database. The waste control operator was in direct communication with waste handlers and operated remote-controlled cameras to view and record the examination process. In addition, differential pressure readings for the glove box, waste handler work area, and HEPA filters were monitored in the control room shown in Figure 8.

Any prohibited items identified during waste examination were removed from the waste stream. Prohibited items included ignitable, corrosive, or reactive characteristic wastes (U.S. Environmental Protection Agency [EPA] waste codes DOO1 through DOO3), pyrophoric nonradioactive materials, liquids, or materials in pressurized containers (e.g., aerosol cans or gas cylinders). These items were segregated and moved to a holding glove box connected to the examination glove box by a pass-through door. Segregated items were placed in holding containers for later disposition and were recorded in the TRU waste characterization database.

Wastes were repacked into DOT-compliant payload containers (208-liter [55-gallon] drums) on an individual waste unit basis. The payload containers were attached to the underside of the glove box with hydraulic lifts. A scale was emplaced underneath the payload container. Waste units were weighed as they were placed in the payload container. Weights were relayed to the waste control operator who recorded the weight on videotape and input this information into the TRU waste characterization database. The sum of individual waste unit weights constitutes the total payload container net weight. A hard copy report was generated for each payload container identifying container contents.

Bechtel Nevada (BN) is committed to Project Management as a basic business philosophy and a primary approach for responsiveness to customer requirements. BN is a corporate member, and many employees are active in the Project Management Institute (PMI). The BN project management process closely mirrors PMI Project Management disciplines (e.g., scope, cost, time, and risk management) which were used in the design and construction of this project.

Success of the WEF project meant meeting all DOE/state- negotiated milestones documented in the Federal Facilities Compliance Act Consent Order within an extremely tight budget and schedule. Technical challenges had to be met through innovation and cost effectiveness. Project planning included formulation of a team of selected DOE, Bechtel Nevada, and subcontractor personnel who were able to commit to "turnkey" services throughout planning, design, and construction. Technical, budget, and schedule objectives were clearly defined at this stage and considered absolute. As a result, project execution planning specifically addressed the following:

• Relocation and use of an existing NTS building to house the characterization work.
• Utilization of off-site consulting firms with specific expertise in TRU waste handling to complement Bechtel-wide experience in containment systems.
• Up-front completion of a hazards assessment, including analyses of specific radiological facility requirements.
• Identification of key containment features and facility systems interfaces.
• Establishment of a "fast-track" schedule that included the initial activities of site design and construction. As these activities progressed, interior systems design were completed, concurrent with procurement of the primary (i.e., glove box) and secondary (i.e., work area) containment systems.
• Preparation and use of a "performance-based" specification to solicit, evaluate, and award a subcontract for the glove box and secondary containment systems. The successful proposer, NFS-Radiation Protection Systems (NFS-RPS), was made part of the WEF team immediately upon contract award.
• Use of on-site field construction labor and equipment to complete interior construction and installation of the containment systems under NFS-RPS oversight.

Detailed planning in support of overall project execution included:

• Creation of a "Bottom-Up" detailed activity and resource-loaded schedule with the critical path clearly identified. This detailed schedule identified activities totaling over 20,000 man-hours of activity, some with as little as 20 man-hours but few over 200 man-hours. Subsequent iterations refined activity links with the goal of reducing critical path duration.
• Buy-in by all "team" members—Customer (DOE); Bechtel Nevada Corporation (BNC) Engineering, Construction, Operations, Management, and NFS-RPS.
• Breakdown of work divisions by bargaining units.
• Use of regular preconstruction and tailgate safety meetings.

The project team weighed the effort required to perform frequent formal tracking of performance, with emphasis on corrective action versus potential cost impacts of overruns and/or schedule delays. Avoiding field problems was determined well worth projected additional tracking costs. The following specific actions were taken:

• Constant "pushing" of the schedule to preclude missed milestones and to reduce or avoid additional costs. The team utilized brainstorming and value engineering-type techniques to address better ways to accomplish technical and construction goals within or ahead of schedule.
• Weekly meetings with a fixed agenda were held to plan, track, and manage the work. The following items were addressed, with action items assigned as needed:

The project team maintained complete commitment to the project activity schedule by:

• Achieving commitment at the management level of all departments involved in the initial development of the project schedule.
• Updating schedule status weekly and continually evaluating how the schedule could be "pushed" the following week. Commitment here was from lead personnel of the different groups.
• Starting each days work with a safety meeting and discussions of planned work activities for that day and several ensuing days. In these "planning" meetings, suggestions from craft personnel were encouraged and often were critical in "beating" the schedule. Most importantly, these meetings solidified schedule "buy-in" one step at a time through all levels of the team.

Commitment to achieving the best cost performance possible mirrored schedule commitment. All team members constantly looked for cost/schedule saving opportunities without sacrificing safety or quality. Various field changes required frequent engineering presence in the field.

The project was completed without personnel injury. Previously mentioned daily safety meetings where held in which activities of the day were discussed. Each of these discussions included specific or special safety actions to be taken. "Watching out for your partner" was continually stressed. Quality was emphasized and rework minimized with discussions focusing on "doing it right the first time."

In addition to procuring the glove box and secondary containment systems through use of a performance specification, several other actions taken by the project team enhanced subcontractor performance. These included:

• Establishment of an aggressive schedule, with vendor selection based in part on meeting/beating the schedule.
• Weekly (or as required) meetings in person or by conference calls which included updating progress and rapid processing of change orders and clarifications.
• Integration of containment system features into field construction "on the fly" as well as vendor oversight of contractor crafts.

Although there were many modifications that changed the construction approach, few actual scope changes were implemented. Only two technical revisions totaling $30,000 were added to the baseline.

The WEF was designed and constructed with installation of all major procured systems in a nine-month period. There were no reportable safety incidences. Total project costs were approximately $105,000 (5.8 percent) under the cost baseline. Most importantly, customer expectations were fully realized. All state agreements were met.

A pilot project was conducted in order to validate the waste examination and repackaging process described in Part I. Scope of the pilot project included both cold and hot operations. Cold operations consisted of training and process walk-downs, while hot operations included examination, segregation, and repackaging of 14 waste drums.

Cold operations which did not involve radioactive materials, began on July 15, 1997. The optimum WEF operations staff included four waste handlers, two radiological control technicians (RCTs), and one waste control operator. The goal of cold operations was to meld these personnel into a cohesive operational team. Since this was a first-of-its-kind operation at the NTS, the approach taken was to train supervisory personnel in all phases of WEF operations. A group of five supervisors was chosen as the primary operational team. Due to the potential hazards involved, RCT support was both critical and integral to the operation. Five RCTs were selected to participate in the pilot project.

The training program was designed to be consistent with DOE Order 5480.20A and required completion of qualification cards for each identified WEF position. These positions encompassed the following responsibilities:

• Site Project Manager (SPM): Manage WEF operations to meet WIPP characterization requirements.
• Site Supervisor: Lead day-to-day operations at the WEF. The waste control operator may serve as the site supervisor.
• Waste Control Operator: Conduct waste characterization activities and acquire data associated with the waste examination and repackaging process.
• RCTs: Ensure operations are conducted in a radiologically safe manner.
• Waste handlers: Examine, segregate, and repackage waste inside the WEF glove box.

Operational personnel could be qualified for more than one position by completing the respective qualification card requirements. Qualification cards included entry-level requirements, required training courses, required reading, and activities in which proficiency had to be demonstrated. The formalized training regimen included glove box operations training, with support provided by personnel from Los Alamos Technical Associates (LATA) from the Rocky Flats Plant in Denver, Colorado. The operations team practiced using simulated waste drums. Individual operator aids were developed to describe the specific details of each process step. Each step was choreographed in full dress, including respirators for those activities where seals could be breached (overpack removal, drum bag-in, and drum bag-out operations). Training culminated with a full-dress critique conducted by personnel from both LATA and Lawrence Livermore National Laboratory (LLNL). The critique, in addition to operational concerns identified by waste handlers, resulted in some facility modifications. In particular, glove box storage capabilities were improved and work area air flow was redirected to limit the volume of air exiting the work area when personnel move in and out of the secondary containment structure. The entire process was videotaped to identify areas for improvement. As a final step prior to working with actual waste drums, a readiness review was conducted by management to ensure that all operational considerations had been addressed. This review identified additional requirements prior to going into a "hot" mode. Resulting action items were completed with hot operations declared ready to commence on September 22, 1997.

The goal of hot operations was to gather data on the effectiveness of the waste examination, segregation, and repackaging operation. Fourteen waste drums, containing an average of four grams of Pu-239, were selected for repackaging. Two of these drums were standards in which the contents, both radiologically and physically, were well known. These drums were used to familiarize the waste handlers with working with actual known waste and to complete waste handler qualification documentation. The other 12 drums were known to contain prohibited items, but the exact physical and radiological makeup of the containers was unknown. Waste in all 14 drums was successfully examined. Prohibited items were identified, segregated, and repacked into DOT-compliant payload containers. Pilot project operations were completed on October 9, 1997.

Pilot project results indicated that the WEF performed as expected. A total of three drums can be examined and repackaged each day through the WEF, with a full-staff complement working ten-hour days. Training for operations personnel was deemed adequate, with no significant or reportable occurrences. However, one glove was punctured during a drum de-lidding operation in the glove box. The punctured glove was replaced successfully without allowing any radioactive contamination to escape. As a result of this lesson learned, steps were implemented to require waste handlers to don steel mesh over-gloves located in the glove box when performing drum de-lidding operations. This precaution protects gloves from being exposed to pinching and puncture hazards. Operations personnel received no internal radiological uptake or whole body doses. A maximum extremity (i.e., hands) dose of 41 millirems was recorded for one waste handler over a one-week period. The average weekly dose to the hands for waste handlers was approximately 20 millirems.

Contamination levels inside the glove box were as high as 2 million disintegrations per minute (dpm) per 100 square centimeters. The glove box was found to be tight, allowing none of this contamination to escape, even when the glove box HEPA unit was shut down during an unplanned power outage. The continuous air monitor (CAM) in the facility did alarm, however, but this was determined to be caused by radon becoming impregnated on the CAM alarm filter paper and was not the result of leakage from the glove box.

Lessons learned from the pilot project will be applied to production operations. These include the following:

• Backup HEPA for glove box. Ideally, the glove box should have a negative air flow pressure applied to it at all times once it goes into a hot status. The current configuration has no hard-wired backup. Therefore, if the glove box HEPA unit fails, negative pressure in the glove box will be lost. The concern here is that a loss of negative pressure in the glove box could precipitate a loss of radiological containment. This could occur if pinhole leaks are present in the glove box gloves or bag ports, or leakage could result from a backflow condition whereby the glove box goes positive with respect to the outer work area. The work area HEPA unit is interlocked with the glove box HEPA unit; therefore, both units will shut down if the glove box HEPA unit shuts down. This interlock reduces the chance of a positive flow condition in the glove box. However, when the wind blows across the facility exhaust stacks, a negative pressure is induced in the WEF work area resulting in a positive flow condition in the glove box. This condition results in air flowing from the glove box to the WEF work area via the glove box input HEPA filters which are located on top of the glove box (refer to Figure 8). If this filter fails or becomes overloaded, contaminated air may enter the work area. Backup HEPA filtration is available through the overpack removal hood unit, but the hood blower has to be manually connected to the glove box ventilation ducting. To address this concern, it is planned to install an auxiliary HEPA unit interlocked to the main unit.
• Drum compaction inside the glove box. During examination and repackaging, it was discovered that some items had been previously compacted inside the waste containers. When these items were removed from the waste container for examination, they expanded to their original volume. This expansion presented difficulties in repacking the waste container contents into a single payload container. Manual compaction using tools in the glove box provided some compaction, but the effort was labor-intensive and inefficient. This problem will be mitigated by adding a mechanical compaction device inside the glove box. Because the glove box is hot, the compaction device must be installed and used in a manner that isolates the glove box interior from the work area.
• The lessons learned during the design and construction phase confirm that strict project management discipline philosophy works. The primary success factor in this is detailed planning of the baselines. The project was not micro-managed, but was micro-planned, resulting in the management activities during execution being much simpler and straightforward. This type of detailed project planning is instituted throughout BN projects.
• Reduced respirator usage. The examination/repackaging process required use of air-purifying respirators any time the potential existed that containment barriers could be breached. This included overpack removal, waste drum bag-in, waste drum bag-out, payload container bag-in, payload container bag-out, glove changes, and material bag-in/bag-out operations. As a result, the efficiency of the overall operation was reduced due to respirator dress-out requirements. The pilot project showed that respirator usage was only required when actual containment seals were manipulated during bag-in/bag-out operations and glove changes. This change will reduce respirator usage by over 50 percent resulting in a greater drum throughput.

The next step in developing the TRU waste characterization program at the NTS is to establish nondestructive examination (NDE), radioassay, and headspace gas sampling capabilities by employing mobile characterization vendors. These vendors are made up of a consortia of companies providing complete characterization services. Two vendor teams are currently being considered: Mobile Characterization Services (MCS) and TRUTECH. The NTS has been designated by WIPP as a demonstration site where mobile characterization vendors are audited and approved by WIPP to provide these services DOE complex-wide. Therefore, the approach taken at the NTS is to utilize these vendors while they are on site for their certification audits. The vendors are scheduled to be audited during March 1998. The NTS program utilizing these vendors will be audited during April 1998. Full characterization operations will commence subsequent to these audits.

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