Joyce L. Connery, Chair

Thomas A. Summers, Vice Chair

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

Washington, DC 20004-2901

February 12, 2024

The Honorable Jill Hruby

Administrator 

National Nuclear Security Administration 

U.S. Department of Energy 

1000 Independence Avenue, SW 

Washington, DC 20585-1000 

Dear Administrator Hruby:

The Defense Nuclear Facilities Safety Board (Board) recently conducted a review of the 

fire protection program at the Pantex Plant. The review evaluated the adequacy of the 

program—including associated safety requirements; fire hazard analyses; fire prevention 

practices; fire protection system inspection, testing, and maintenance; and fire department 

response—against U.S. Department of Energy (DOE) and industry standards. 

Overall, the Board found that Pantex is implementing an adequate fire protection 

program, with all expected major components, consistent with DOE safety requirements and 

expectations. The review identified opportunities for improvement and several best practices, 

which are discussed in the enclosed report for the National Nuclear Security Administration’s 

information and use.

Sincerely,

Joyce L. Connery

Chair

Enclosure

c: The Honorable Jennifer Granholm, Secretary of Energy

 Ms. Teresa Robbins, NNSA Production Office Manager

 Mr. Jason Armstrong, NNSA Production Office Manager at Pantex

 Mr. Joe Olencz, Director, Office of the Departmental Representative to the Board
DEFENSE NUCLEAR FACILITIES SAFETY BOARD

Staff Report

November 8, 2023

Review of the Pantex Plant Fire Protection Program

Summary. Members of the Defense Nuclear Facilities Safety Board’s (Board) staff 

conducted a review of the Pantex Plant fire protection program, with a focus on (1) program 

administration; (2) fire hazard analyses; (3) wildland fire; (4) fire protection system inspection, 

testing, and maintenance; (5) high pressure fire loop performance and upgrades; 

(6) administrative controls; and (7) emergency services.

The staff review team found the program to be adequately established and generally 

functioning well. The staff review team did identify some opportunities for improvement related 

to fire protection system impairments, false alarms, and requirements for manual fire 

extinguisher use within the Pantex technical safety requirements (TSR).

Background. On March 28–31, 2022, the staff review team met on-site with personnel 

from the Pantex management and operating contractor, Consolidated Nuclear Security, LLC 

(CNS), and the National Nuclear Security Administration Production Office (NPO) to discuss 

detailed lines of inquiry related to the fire protection program, visit applicable facilities, and 

observe fire department response during an emergency exercise.

The staff review team had numerous follow-up questions, requiring the team to request 

and review a significant number of additional documents. The staff review team followed up 

with a March 29, 2023, teleconference with NPO and CNS personnel. The staff review team 

also held factual accuracy teleconferences on July 12 and July 26, 2023, to ensure that the team 

properly characterized its observations.

Discussion. The staff review team identified the following opportunities for 

improvement:

Fire Protection System Impairment Communication—Pantex currently uses a 

continuously updated form, Fire System Impairment Status Report, PX-5699, to track fire 

protection system impairments [1]. Due to the way this form is maintained, the notification to 

the Emergency Services Dispatch Center (ESDC) on impairments is not always timely. 

Consequently, communications of impairment changes among CNS Fire Protection Engineering, 

the Impairments and Restoration Group, and ESDC sometimes experience notification lag. CNS 

stated that when notification lag has occurred, it was typically on the order of a day or so 

between the start of impairment and the time of notification.1

1 The staff team found that impairments to nuclear facility systems require additional clearances/reviews and are 

much less likely to experience delayed communication of impaired status.
2

Knowledge of impaired systems and alarms is particularly important to ESDC, as these 

could delay or hamper emergency response. For example, an impaired fire hydrant could affect 

emergency responders if they attempt to use it because they are unaware that it is out of service. 

CNS is undertaking a new effort to separate fire alarm signal issues that directly impact dispatch 

from other impairments. This effort includes repurposing form PX-5699 to include only fire 

alarm signal information, as well as continued use of a new separate fire protection engineering 

spreadsheet to track system impairments. CNS’s goal is to provide immediate notification to 

ESDC for all fire system impairments. The staff review team agrees with this goal given the 

potential impact on emergency response.

In addition to delays in notifying ESDC, the current impairment data categorization is not 

conducive to prioritize repairs. For example, there is little differentiation between short-term and 

long-term impairments, which can be used as a part of prioritization. Figure 1 shows the length 

of impairments in the short-term, long-term, and fire hydrant categories from Pantex impairment 

data. As seen in Figure 1, there is significant overlap in the length of impairments considered 

“short-term” and “long-term.” The fire hydrant category in the figure demonstrates that these 

impairments could be considered either short- or long-term.

Poor categorization of impairments can hamper proper prioritization of repairs to 

impaired systems. CNS stated that a part of the new effort to track impairments will include 

redefining what constitutes a short- or long-term impairment, as well as additional 

categorization. CNS has already made some improvements to impairment data categorization, 

such as removing abandoned systems from the long-term category. The staff review team agrees 

with this approach and considers that additional study of impairment data categorization could 

further improve prioritization of repairs. 
3

Figure 1. Comparison of Short-Term and Long-Term Impairments
4

Unresolved Signals Disposition—The number of facilities with unresolved signals has 

been consistently unsatisfactory per site goals.2 Unresolved signals are fire alarm-type signals 

that are active but have not yet been addressed. Typically, these signals are trouble or 

supervisory conditions such as ground faults or valve monitoring problems, as opposed to 

alarms. In the summer of 2022, CNS implemented an updated prioritization scheme and 

dedicated a crew of craft workers to resolving fire protection system issues, including unresolved 

signals. Under this updated scheme, the number of facilities with unresolved signals has been 

reduced through a combination of correcting problems and temporarily suppressing signals. This 

suppression method, termed “resistoring out” in the impairment data, involves installing an endof-line resistor in the device wiring circuit to force the device to report a normal condition to the 

fire alarm panel.

The primary concern with suppressing a fire alarm trouble or supervisory signal is that 

the status of the device will no longer be known, which could delay notification of a pending 

problem or system degradation. For example, a low-pressure switch on a dry pipe sprinkler 

system provides an indication that the system is losing pressure and could trip soon. If this 

occurred during winter, the tripped valve could charge the system with water in very cold 

conditions, potentially leading to pipe freeze. Notification would only occur via a flow switch 

when water is already moving into the cold pipes. CNS stated that most of the cases in which 

end-of-line resistors have been installed are for difficult to repair issues and consist mostly of 

tamper switches on post indicator valves for the underground fire mains. In this case, the tamper 

switch will not report when the valve is closed; however, the valves can be administratively 

controlled (i.e., locked open) and are less of a concern than other devices such as the pressure 

switch example mentioned above.

The monthly metrics data report from April 2023 [2] states that 35 of 54 devices with 

end-of-line resistors installed were for post indicator valves. Some of the remaining 19 devices 

from the report are devices other than valve tamper switches, which may not have available 

administrative controls that are as easy and effective as the one for valves. The staff review team 

is aware that NPO is actively engaged with CNS in addressing the number of unresolved signals.

High Number of False Alarms—The percentage of Pantex fire department calls that are 

false alarms is high compared to national data provided by the National Fire Protection 

Association (NFPA). Table 1 provides basic data on the number of Pantex fire department calls 

and false alarms between 2017 and 2021. Depending on whether mutual aid calls are included in 

Pantex false alarm data, the percentage of calls that are false alarms ranged between 32 and 58 

percent from 2017 to 2021. (Note that the percentage of calls that are false alarms is greater 

when mutual aid calls are excluded.)

2 The number of facilities with unresolved signals had typically been much greater than the goal of 30. After 

implementation of an updated prioritization scheme in 2022, the number of facilities decreased steadily to between 

15 and 20 in early 2023. CNS subsequently lowered the goal to 17 facilities with unresolved signals.
 

5 

Table 1. Pantex False Alarm Data 2017-2021

Year False 

Alarms

Total 

Annual 

Calls

Total Annual Calls 

without Mutual 

Aid Calls

False Alarm %

(all calls)

False Alarm %

(without mutual aid 

calls)

2017 179 369 308 49 58

2018 125 387 303 32 41

2019 154 409 331 38 47

2020 116 358 296 32 39

2021 171 406 314 42 55

NFPA collects annual nationwide fire department response statistics, including the 

number of false alarm responses. Between 1980 and 2021, the percentage of fire department 

responses attributed to false alarms has varied from 7 percent to 11 percent of all responses in 

any given year [3]. Between 2017 and 2021, the percentage of alarm responses attributed to 

false alarms was 7 to 8 percent, which is less than that observed at Pantex.

NFPA response statistics also include a broad category entitled “All Other Responses” 

with examples such as smoke scares and lockouts, which could include some false alarms. 

Between 1980 and 2021, the percentage of fire department responses included in this category 

has varied from 10 percent to 18 percent of all responses in any given year. Though all 

responses in this category are very unlikely to be considered the result of false alarms, adding the 

“all other responses” to the false alarm responses yields a maximum possible nation-wide 

nuisance alarm response of approximately 26 percent. This false alarm response rate is still 

lower than the 32 to 58 percent observed at Pantex. 

Minimizing false alarms is important because they could delay response to an actual 

emergency if they occur at the same time. Time taken to respond to false alarms could also be 

better spent on other endeavors such as training or inspections. CNS stated that the main sources 

of false alarms at Pantex are water flow alarms associated with system surges and dry pipe trips, 

inadvertent duct smoke detector alarms, manual fire alarm pull station malfunctions, and fire 

panel malfunctions. CNS stated that it has made progress in reducing false alarms associated 

with water flow alarms, which constitute the bulk of false alarms at the site. However, even with 

this reduction, the false alarm rate is still high and warrants further investigation to determine 

whether the rate can be reduced.

Use of Manual Fire Extinguisher in TSRs—The current TSRs for Pantex [4] incorporate 

an operator action of manually extinguishing a fire in defense nuclear facilities. The TSRs 

should not rely on operator actions that are broadly considered optional (i.e., fighting a fire). 

TSR section 5.7.33.7.1.b states the following operator actions for personnel routinely performing 

work in the facility:
 

6 

If the fire has not involved nuclear material, personnel should attempt to 

extinguish the fire using a fire extinguisher or other method and move any 

[Thermally Sensitive Components (TSCs)] away from the fire; or if unable to 

extinguish the fire, move the TSCs away from the fire, manually activate the 

Deluge Fire Suppression System, if one exists, and if the bay inner interlock door 

can close, close the door, and evacuate the facility [emphasis added].

The training materials for this TSR [5, 6] incorporate similar “should attempt to 

extinguish” language, which suggests an expectation that personnel will attempt to extinguish 

some fires. However, the site fire extinguisher training [7] uses the more permissive language: 

“Personnel may choose to extinguish the fire or evacuate the facility” [emphasis added]. The 

fire extinguisher training is consistent with traditional fire protection philosophy, which 

emphasizes that attempting to manually extinguish a fire is a personal choice.

CNS reiterated that personnel always have a choice whether to attempt to extinguish the 

fire or to evacuate the facility. For nuclear explosive facilities, if personnel are uncomfortable 

attempting to extinguish a fire, they are allowed to evacuate and manually activate the deluge 

suppression system. At the time of this review, CNS was revising the TSRs to remove this 

requirement and provided a proposed safety basis change package to NPO for review. If 

approved, CNS plans to implement the requirement changes in 2024. 

Observations. During its review, the staff team also identified the following:

Fire Hazard Analysis (FHA) Discussion of Building Code Occupancy—FHAs for 12-116 

[8] and 12-104 [9] do not currently include a discussion in Chapter 2 on occupancy type, 

area/height limitations, and required separations as they relate to the International Building Code 

and/or Uniform Building Code. These FHAs inappropriately conclude that the facility 

construction meets requirements of national consensus codes (including building codes) without 

including this discussion. This approach is also inconsistent with other Pantex FHAs, which 

include the information. For example, the 12-64 FHA [10] includes a detailed discussion on 

International Building Code occupancy types in the facility. This discussion includes the 

potential application of high-hazard (H-3), storage (group S), and industrial (F-2) occupancies, 

with a focus on the presence of explosives or other operations. Specific height and area 

limitations are also described along with required fire separations for these occupancy types. 

This staff observation is not meant to convey a building code-compliance issue with 12-116 and 

12-104, but rather that the FHA discussion on these topics is incomplete. 

Confusing Presentation of Metrics for Preventive Maintenance (PM)—The monthly 

report of fire protection metrics notes fire system PM activity in terms of “Overdue PMs,” “New 

PMs,” “Completed PMs,” and “Cancelled PMs.” Figure 2 shows an example of the presentation 

of monthly PM metrics.
 

7 

Figure 2. Categorization of Preventive Maintenance in Monthly Metric Report [2] 

As suggested by the category title “Cancelled PMs,” it appears that CNS cancelled fire 

protection maintenance activities on a regular basis. CNS clarified that the category of

“Cancelled PMs” in the Pantex site fire protection maintenance data consists of two 

subcategories:

1. Nested maintenance tasks that are conducted as part of longer-period activities. For 

example, quarterly maintenance tasks may be conducted as part of semi-annual and 

annual tasks, so those quarterly tasks are cancelled within the maintenance tracking 

system.

2. Scheduled maintenance tasks that are cancelled within the system and subsequently 

not performed. 

CNS stated that most, if not all, “Cancelled PMs” fall into the first category, and that no 

systems in defense nuclear facilities fell into the second category. While the staff review team 

now understands this nuance, CNS should consider revising the presentation of PM data in the 

monthly metric report to more clearly depict how many PMs are cancelled and not performed. 

[sic]
8

Misalignment of Combustible Control Procedure and Combustible Loading Dispositions 

(CLD)—There is general alignment with the CLDs and the combustible control procedure, 

P7-0040 [11]. However, there are some instances where P7-0040 lists a combustible standoff 

distance but there does not appear to be any related distance provided in the CLD. To ensure fire 

safety is maintained, the technical basis for combustible standoff distances must be properly 

documented. Examples where CLDs omit standoff distances used in P7-0040 include CLD-005, 

LINAC Bays Combustible Loading Disposition [12], and CLD-006, Mass Properties 

Combustible Loading Disposition [13].3

 CNS stated that the information in procedure P7-0040 

is accurate and that some CLDs require updating to match this document. CNS is undertaking a 

broader look at CLDs and is updating them as a part of a combustible controls safety basis 

improvement initiative.

Fire Alarm Ground Fault Testing—The annual fire alarm maintenance procedure [14] 

does not include testing of alarm functions during a system ground fault condition, as required by 

NFPA 72 [15]. To ensure proper operation of fire alarm systems, testing required by NFPA 72 

must be performed. CNS stated that this test is conducted only during initial system acceptance 

but agreed that NFPA 72 could be interpreted to require this test annually. CNS is seeking a 

formal interpretation from NFPA on this issue and will determine a path forward once NFPA 

provides an answer.

Best Practices. The staff review team identified the following best practices and 

improvements implemented prior to and during the course of this review.

Fire Damper Evaluation and Documentation—In 2014, Pantex declared a TSR violation 

when a fire protection engineer discovered no fire damper within the task exhaust duct that 

breached a credited fire barrier within a special nuclear material facility. As a corrective action, 

Pantex conducted extent of condition reviews that identified other missing fire dampers within 

defense nuclear facilities and safety concerns over maintaining difficult-to-access dampers. Over 

several years, Pantex evaluated each credited fire damper to determine an appropriate path 

forward and implemented solutions, which included installation of new dampers, improving 

access to existing dampers, and providing technical justifications where new dampers would not 

be installed.

The staff review team has been following this effort closely and found the ultimate 

solutions to be appropriate and now nearly complete. CNS is working to incorporate the 

remaining technical justifications into some FHAs for not installing new fire dampers in certain 

locations. Of note, CNS has modified three FHAs to incorporate detailed disposition of fire 

damper issues into the text, including the FHAs for 12-44 [16], 12-64 [10], and 12-86 [17]. For 

other FHAs—i.e., the FHAs for 12-84 [18], 12-85 [19], 12-96 [20], 12-98 [21], 12-99 [22], and 

12-104 [9]—CNS has appended a detailed fire damper checklist (form PX-4453) containing 

similar information to that incorporated into the 12-44, 12-64, and 12-86 FHAs. CNS plans to 

3 Omitted standoff distances in CLD-005 include those for empty, approved non-combustible containers, including 

associated foam lining/packaging and Celotex packing material, and items in Section 4.2.38. Omitted standoff 

distances in CLD-006 include those for the PCMA computer terminal and associated combustibles; empty approved 

containers opened with packaging material exposed; HFE-7100 IPA solvent (nonflammable) in Repipet II container 

with plastic dispenser; and gloves and packaging materials.
9

incorporate the detailed information from the PX-4453 forms into the body of the FHAs during 

the next update.

Fire Suppression System Maintenance Procedure Updates—CNS is revising the series of 

fire suppression system maintenance procedures to incorporate various improvements. For 

example, CNS intends to:

• Use the NFPA 25 [23] pressure-change threshold for investigating potential problems 

(i.e., 10 percent change from prior test versus the previous 20 psi threshold). CNS 

has since implemented this change within the applicable maintenance procedures.

• Incorporate locations to record observed pressures in the procedure. CNS stated that 

this has been completed for the 12-44 procedures. The semi-annual, annual, and fiveyear maintenance procedures for other facilities are in the process of being updated.

• Incorporate specific valve identifiers in procedures. The configuration-controlled 

drawings for fire suppression systems and valves in the field are being updated to 

include specific valve labels as the Bay and Cell Upgrade Project progresses. CNS 

stated that all procedures have been updated to include specific valve identifiers, with 

the exception of 12-44 Cells 2, 3, and 4.

FHA Preparation Guide Updates—CNS has improved the preparation guide for updating 

FHAs at Pantex. Specifically, the guide [24] now describes the need to analyze the fire 

vulnerability of critical safety systems, as well as detail the protection of ventilation inlets from 

wildland fire embers.

Suppression System Freeze Protection—After a site freeze event in February 2021, CNS 

implemented specific preventive measures to address freezing of water-based fire suppression 

systems. These measures include providing additional heating or draining sprinkler systems in 

applicable locations. CNS has installed additional permanent heating in some facilities and will 

employ temporary heating in other facilities when necessary. CNS would drain systems as a 

last-resort effort. For defense nuclear facilities with safety-related sprinkler systems covered by 

TSRs, entry into limiting conditions for operation would be required when impairing the system. 

This limiting condition for operation includes the following required actions:

• Placing material-at-risk into a safe and stable configuration;

• Taking other actions as necessary to protect material-at-risk from fire events in the 

affected area;

• Establishing a fire watch or reducing/removing/containerizing combustibles; and

• Placing the facility in maintenance mode.

The staff review team is aware that use of these compensatory measures for freezing 

conditions has not been required generally within defense nuclear facilities at Pantex (with the 

current exception of 12-64), as their fire suppression systems are less likely to be subjected to 

freezing conditions.
10

High Pressure Fire Loop (HPFL) Monitoring—CNS actively monitors the status of the 

HPFL system, including valve status and leak rate, which helps to ensure that the required water 

pressure and flow rate are available to defense nuclear facilities. The site tracks valve closures 

using a digital “HPFL Status Board”4 that shows the impact of closures on the system. In 

addition to the status board, the CNS Fire Protection Engineering group maintains a complete 

hydraulic model of the system [25], which allows an assessment of valve closure impacts. CNS 

also has live leak rate monitoring capability to ensure that HPFL issues are detected before the 

system approaches its TSR leak rate operability limit of 200 gallons per minute.5

Fire Department Staff Involvement—The Pantex Fire Department has endeavored to 

involve staff in the fire protection program, which helps to bolster staff buy-in. Postings of 

monthly fire department metrics have been prominently displayed in the main fire house for 

communication to staff. The department also involved staff in selecting options for new 

apparatus, to best serve the needs of the responders.

Conclusions. The staff review team found that Pantex is implementing an adequate fire 

protection program, with all expected major components, consistent with DOE requirements and 

expectations. The review team identified some opportunities for improvement—related to fire 

protection system impairments, false alarms, and TSR requirements for manual fire extinguisher 

use—as well as observations and best practices.

4 The HPFL Status Board is maintained by the Operations Center and is verified at least weekly by the CNS Fire 

Protection Engineering group.

5 Typically, the leak rate is 30-40 gallons per minute. When the leak rate rises above this threshold, CNS initiates an 

investigation into the cause.
 

R-1 

References

1. Consolidated Nuclear Security, LLC, Fire System Impairment Status Report, PX-5699, 

Issue No. 6, Accessed November 2, 2022. 

2. Hahn, Justin, Monthly NPO Fire Protection Meeting – April 2023, Consolidated Nuclear 

Security, LLC, April 2023. 

3. National Fire Protection Association, Fire Department Calls, https://www.nfpa.org/Newsand-Research/Data-research-and-tools/Emergency-Responders/Fire-department-calls, 

National Fire Protection Association, Quincy, MA, Accessed May 24, 2023. 

4. Consolidated Nuclear Security, LLC, Technical Safety Requirements for Pantex Facilities, 

RPT-SAR-199801, Revision 466, January 17, 2022. 

5. Consolidated Nuclear Security, LLC, TSR Control Training, CR 541.45, Revision 015, 

August 30, 2021. 

6. Consolidated Nuclear Security, LLC, Infrastructure TSR Controls, CR 190.62, Revision 

06A, August 16, 2021. 

7. Consolidated Nuclear Security, LLC, Fire Extinguisher Safety Training, JT 60.21, 

Revision 000, September 12, 2019. 

8. Consolidated Nuclear Security, LLC, Fire Hazard Analysis for Bldg 12116 Special 

Nuclear Material (SNM) Component Staging Facility, FHA-12116, Issue No. 010, July 

12, 2022. 

9. Consolidated Nuclear Security, LLC, Fire Hazard Analysis for Building 12-104 High 

Explosives Subassembly Facility, FHA-12104, Issue No. 006B, March 22, 2022. 

10. Consolidated Nuclear Security, LLC, Fire Hazard Analysis for Bldg 12-064 Assembly and 

Staging Bays, FHA-12064, Issue No. 007, May 12, 2022. 

11. Consolidated Nuclear Security, LLC, Combustible Material Controls, P7-0040, Issue BO, 

June 20, 2022. 

12. Consolidated Nuclear Security, LLC, LINAC BAYS Combustible Loading Disposition, 

CLD-005, Issue No. 005, April 8, 2020. 

13. Consolidated Nuclear Security, LLC, MASS PROPERTIES Combustible Loading 

Disposition, CLD-006, Issue No. 007, June 28, 2021. 

14. Consolidated Nuclear Security, LLC, Electrician’s Fire Protection System, Annual, 

Building 12-44, TP-MN-03468, Issue 33, July 5, 2022. 

15. National Fire Protection Association, NFPA 72 - National Fire Alarm and Signaling 

Code, National Fire Protection Association, Quincy, MA, 2022 edition. 
R-2

16. Consolidated Nuclear Security, LLC, Fire Hazard Analysis for Building 12-44 Cells 002-

006 Assembly/Disassembly of Weapons, FHA-12044 C002-006, Issue No. 007, April 12, 

2022.

17. Consolidated Nuclear Security, LLC, Fire Hazard Analysis for Bldg 12-086 SNM 

Component Requalification & Inert Assembly and Testing Facility, FHA-12086, Issue No. 

005B, July 8, 2022.

18. Consolidated Nuclear Security, LLC, Fire Hazard Analysis for Bldg 12-084 Assembly 

Bays, FHA-12084, Issue No. 007B, March 17, 2022.

19. Consolidated Nuclear Security, LLC, Fire Hazard Analysis for Bldg 12-085 Nuclear 

Explosive Cell, FHA-12085, Issue No. 006F, March 17, 2022.

20. Consolidated Nuclear Security, LLC, Fire Hazard Analysis for Bldg 12-096 Nuclear 

Explosive Cell, FHA-12096, Issue No. 009A, March 21, 2022.

21. Consolidated Nuclear Security, LLC, Fire Hazard Analysis for Bldg 12-098 Nuclear 

Explosive Cells, FHA-12098, Issue No. 006D, March 21, 2022.

22. Consolidated Nuclear Security, LLC, Fire Hazard Analysis for Bldg 12-099 

Assembly/Disassembly Bays, FHA-12099, Issue No. 007B, March 22, 2022.

23. National Fire Protection Association, NFPA 25 - Standard for the Inspection, Testing, and 

Maintenance of Water-Based Fire Protection Systems, National Fire Protection 

Association, Quincy, MA, 2023 edition.

24. Consolidated Nuclear Security, LLC, Guide for the Preparation of Fire Hazards Analysis, 

DESKAID-0110, Issue No. 010, April 2020 (estimated).

25. Consolidated Nuclear Security, LLC, Hydraulic Calculations for Nuclear Facilities 

Supplied by the HPFL, EC-08-020, CM Issue No. 001, April 13, 2022.