HD 22/08: Managing Geotechnical Risk Implementation Guidance Wales

Transcription

1 HD 22/08: Managing Getechnical Risk Implementatin Guidance Wales DMRB December 2009

2 1 Intrductin 1.1 Why Getechnical Certificatin? Grund-related prblems can adversely affect prject cst, cmpletin times, prfitability, health and safety, quality and fitness fr purpse, and can als lead t envirnmental damage. Getechnical risk is the risk t building and cnstructin wrk created by the hazards assciated with site grund cnditins. Getechnical risks are nly ne part f ttal prject risks. Hwever, multidisciplinary teamwrk invlving all stakehlders including early input frm a Getechnical Specialist will ensure that prject risks are identified and then vercme r managed efficiently. Getechnical certificatin is used t ensure that grund related hazards are identified and the assciated risks effectively managed t mitigate the ptential adverse effects that they can cause. Practive management f getechnical risk will add value t yur prject whilst cmpliance with HD22/08 will als prvide an audit trail that will avid unintentinal departures frm standards. Ttal prject csts are likely t be reduced. 1.2 Sme definitins The key getechnical rles invlved in the certificatin prcess are the Designer s Getechnical Advisr (DGA) and the Overseeing Organisatin s Getechnical Advisr (OOGA). Thse appinted t the abve rles shall bth have the experience f a Getechnical Adviser as fllws: A Getechnical Adviser is: A Chartered Engineer r Chartered Gelgist with a minimum f five years practice as a Getechnical Specialist. A Getechnical Specialist is: A Chartered Engineer r Chartered Gelgist with a minimum f five years practice in getechnics pst chartership; r A Chartered Engineer r Chartered Gelgist with three years practice in getechnics pst chartership plus a pstgraduate qualificatin in getechnical engineering r engineering gelgy equivalent t an MSc. The Overseeing Organisatin fr the trunk rad netwrk in Wales is the Welsh Assembly Gvernment. 1.3 When des HD22/08 apply? All prjects where Getechnical Activities are invlved shall be certified. Getechnical Activities shall include withut limitatin, the design, cnstructin and maintenance f: a) Earthwrks. b) Strengthened Earthwrks. c) Grund Investigatins, bth intrusive and nn-intrusive. d) Excavatin/assessment belw sub-base level. e) Earth retaining structures. f) Structural fundatins and excavatins. g) Excavatins fr tunnels and service ducts. This is a brad definitin and cnsequently many schemes are likely t require certificatin in line with HD22/08. If the getechnical risks are lw, hwever, then the burden f certificatin can be reduced by agreement between the DGA and OOGA n a case by case basis. 1.4 Scpe and applicatin HD 22/08: Managing Getechnical Risk (DMRB 4.1.2) Implementatin Guidance Wales Issue1, Revisin 1 January

3 HD22/08 applies t: Ntes. a) Prjects prmted by the Assembly Gvernment, Rads and Prjects Divisin (R & P D), where it is respnsible fr prcurement f bth design and cnstructin. This wuld generally cmprise the Trunk Rad Frward Prgramme. b) Prjects prmted by the Welsh Assembly Gvernment, R & P D, where the design and cnstructin prcurement is the respnsibility f a Third Party. This wuld generally cmprise prjects undertaken by the three Trunk Rad Agencies and Traffic Wales. (i) c) Thse parts f prjects prmted by a Third Party where they adjin r therwise affect the Welsh Trunk Rad netwrk. This wuld generally cmprise prjects undertaken by utility cmpanies. (ii) d) Planning applicatins/prjects referred t the Welsh Assembly Gvernment fr directin where they adjin r therwise affect the Welsh Trunk Rad netwrk. (iii) e) Prjects where getechnical infrmatin is required as part f assessment, design and r remedial wrks fr structures cvered by BD2 (Technical Apprval f Highway Structures (DMRB 1.1)). (iv) f) Installatin by trenchless r ther techniques f service crssings. BD2 requires getechnical certificatin in supprt f Apprvals in Principle (AiP). AiPs are required fr service tunnels with an excavated bre diameter greater than 900mm. HD22/08 requires getechnical certificatin fr any tunnel installed using trenchless techniques where the internal diameter is less than 2000mm. In shrt all trenchless wrks including tunnelling require getechnical certificatin. g) The design f remedial wrks t rectify defects affecting the Getechnical Asset (v) which is defined as a principal asset f the highway netwrk, cmprising the fundatins t pavement and structures, tgether with land within the highway bundary thrugh which the rute is frmed (including cuttings, embankments, pavement subgrade and a diverse range f natural gelgical strata and man-made materials). h) Temprary wrks invlving getechnical activities that affect the Assembly Gvernment s asset. (vi) i. T facilitate the Trunk Rad Agencies ability t practively manage getechnical risks n the Welsh Trunk Rad netwrk the Assembly Gvernment is cnsidering develpment f a Welsh Assembly Getechnical Data Management System (WAGDMS). ii. In agreement with the Welsh Highways and Utilities Cmmittee (HAUC) the Natinal Street Gazetteer (NSG)) shuld include details f getechnical difficulty n the Trunk Rad netwrk t flag up particular getechnical hazards and assciated risks which will require management by implementatin f the requirements f HD22/08. This culd be under the sectin n Special Engineering Difficulty r in the Restrictin n Wrks sectin. Nte that 3rd party installatins beneath mtrways and trunk rads require a Sectin 61 agreement under the New Rads and Street Wrks Act (NRSWA). This ensures that all the cst f certificatin is brne by the third party. iii. Assembly Gvernment Develpment Cntrl fficers shuld btain sufficient advice t assess the Getechnical Categry f the scheme applied fr (see sectin 3). Where it is cnsidered that prjects/planning applicatins represent a significant risk t the Assembly Gvernment s asset they shuld be classified as Getechnical Categry 2 r 3 and a planning cnditin shuld be recmmended alng the lines f The develper shall cmply with the requirements f the Design Manual fr Rads and Bridges (DMRB), HD22 Managing Getechnical Risk and shall submit required reprts fr review and certificatin by the Welsh Assembly Gvernment s appinted Getechnical Advisr. Where it is cnsidered that prjects/planning applicatins represent nly a minr risk they shuld be classified as Getechnical Categry 1 and a planning cnditin recmmended alng the lines f N wrks shall be undertaken which culd in any way affect the adjacent trunk rad. T discharge this cnditin, details f the applicant s prpsals in the temprary and permanent case shuld be reviewed by the OOGA wh will review the Getechnical Classificatin and prvide cmment as apprpriate n the wrks prpsed. Nte that the OOGA may cnclude that the presented details are sufficient t discharge the planning cnditin r may re-classify the scheme t Getechnical Categry 2 r 3.. iv. HD22/08 des nt generally apply t structures cvered by BD94/07 (Design f Minr Structures (DMRB 2.2.1) thugh where fundatins are n slpes the stability f the grund needs t be taken int accunt and specialist getechnical advice shuld be sught. v. The prcedures t be fllwed fr risk management f getechnical assets (see HD41 (DMRB 4.1.3) Maintenance f highway getechnical assets) are thse detailed in HD22/08. Whilst the wrks prpsed cmprise nly inspectins HD22/08 shuld be taken as guidance nly. Hwever, the reprting and certificatin requirements f HD22/08 shuld be initiated as sn as grund HD 22/08: Managing Getechnical Risk (DMRB 4.1.2) Implementatin Guidance Wales Issue1, Revisin 1 January

4 vi. investigatins (including installatin f any mnitring regime) r remedial/preventative wrks are prpsed. The DGA will need t ensure that getechnical risks assciated with temprary wrks are included in the Getechnical Risk Register and are cnsidered and managed in principle (nting that the design f them will remain with the Cntractr) t mitigate adverse effects t the prject including, but nt limited t, ttal cnstructin cst and cnstructin health and safety risks. The DGA and OOGA shuld be prvided with an pprtunity t review and cmment upn the Cntractrs temprary wrks design prir t cnstructin. 2 Management f Getechnical Risks 2.1 Getechnical risks and hazards T be effective in terms f managing getechnical risks s as t mitigate ptential adverse impacts n prjects (and ptentially identifying pprtunities fr adding value t a scheme) getechnical risk management shuld be cmmenced as sn as pssible fllwing prject identificatin. The establishment, develpment and refinement f the Getechnical Risk Register is an essential tl t aid management f getechnical risk whilst als prviding effective cmmunicatin f such risks t ther members f the design team t ensure that getechnical risks are nt managed in islatin. Appendix D f Standard HD41 ((DMRB 4.1.3) Maintenance f highway getechnical assets) prvides advice n what cnstitutes ge-hazards that pse risks and will therefre need t be cnsidered when develping the Getechnical Risk Register fr a prject. The advice given in that standard is reprduced belw. The principal getechnical hazards which affect Highway Getechnical Assets, and which may als affect the ther principal assets f the netwrk may be summarised as including: i. Instability in natural and man made slpes f sil, rck, and fill. ii. Weak and cmpressible strata iii. Adverse grundwater cnditins due t changes in the grundwater regime, r t defective drainage, and which may influence material behaviur. iv. Scur and ersin -frm adjacent watercurses, and frm temprary flding. v. Instability assciated with active r ancient disslutin features, fr example, in calcareus rck frmatins (particularly chalk [limestne in Wales]) but als thse cntaining salt and gypsum. vi. The instability f frmer mine wrkings r mine entries affecting the land surface. vii. Subsidence due t current r future mining. viii. Instability and subsidence due t landfill. ix. Grund and grundwater chemistry and the ptential adverse effects n cnstructin materials (e.g. sulphate attack n buried cncrete, including the thaumasite frm f sulphate attack). x. The effect f ptential leachate frm adjacent landfill, and minewater issues fllwing the cessatin f pumping. xi. Highway drainage acting as a cnduit fr the migratin f leachate frm landfill sites. xii. Expiratin f the design life f sil nails, gegrids r ther engineering materials r wrks. xiii. The destabilising effect f animal burrws. xiv. The destabilising effects that can result frm vegetatin, r the remval f vegetatin. xv. Instability resulting frm changes in lading, r any ther changes frm the riginal design assumptins. The ptential impact f the prpsed wrks (in the permanent r temprary case) n third party assets shuld als be cnsidered and the getechnical risks managed s as t minimise the risk f third party claims. Such risks shuld be included in the Getechnical Risk Register and will be subject t this getechnical certificatin prcess. Secndary activities ffset frm the principal cnstructin wrks and the highway asset but that entail getechnical risk (eg develpment and restratin f brrw pits) will nt be the subject f getechnical certificatin thugh the DGA shuld ensure that the getechnical risks are apprpriately managed. 2.2 Key stages in getechnical certificatin HD 22/08: Managing Getechnical Risk (DMRB 4.1.2) Implementatin Guidance Wales Issue1, Revisin 1 January

5 The table belw summarises the Key Stages t be fllwed t ensure the prcurement f the getechnical infrmatin necessary t undertake an accurate assessment f prject risks tgether with the five reprts that underpin the certificatin prcess. Key Stage Title Getechnical reprting requirements Key Stage 1 Initial Review f Prject Statement f Intent (SOI) Key Stage 2 Preliminary Certificatin Preliminary Surces Study Reprt (PSSR) Grund Investigatin Reprt (GIR) Key Stage 3 Getechnical Design and Getechnical Design Reprt (GDR) Cnstructin Certificatin Key Stage 4 Getechnical Feedback Getechnical Feedback Reprt (GFR) Further guidance n the requirements f each stage is prvided in sectins 3 and 4 belw. 3 Getechnical Certificatin Prcedures 3.1 Getechnical classificatin and getechnical reprting and certificatin requirements In rder t establish the Getechnical Certificatin requirements f a prject it shall be reviewed at prject inceptin t determine its Getechnical Categry which is based n a cnsideratin f prject cmplexity, prpsed getechnical activities, presence f ge-hazards and severity f getechnical risks. The Getechnical Categry f a scheme shall be reviewed as additinal getechnical data is prcured and revised as necessary which may result in a change t reprting requirements. The table belw prvides a summary f the Getechnical Categries including ntes n assciated reprting requirements and certificatin. Getechnical Categry Prject details Reprting requirements and certificatin i. Nne N getechnical activities invlved (see sectin 1.3) HD22/08 des nt apply and the prject file shuld be anntated accrdingly. Getechnical Categry 1 Getechnical Categry 2 Getechnical Categry 3 Small and relatively simple structures, earthwrks and getechnical activities. Getechnical activities/structures with negligible risk f verall stability, grund mvements and knwn grund cnditins. N r straightfrward excavatin belw water table. Cnventinal types f getechnical structures, earthwrks and activities N exceptinal getechnical risks, unusual r difficult grund r lading cnditins. The majrity f getechnical activities with highways shuld fall int this categry. Prjects which invlve getechnical activities r structures which fall utside the limits f Categries 1 and 2. These prjects include very large, unusual r cmplex getechnical activities, earthwrks and structures r thse invlving abnrmal getechnical risks r unusual r exceptinally difficult grund cnditins. A separate PSSR is nt required and may be cmbined with the GIR. A reduced scpe GFR is apprpriate and can be agreed with the OOGA. Full cmpliance with HD22/08. Separate PSSR and GIR are required. Full cmpliance with HD22/08. Separate PSSR and GIR are required. Nte: i. All cmpleted reprts and assciated getechnical certificates shuld be filed n the prject file and scheme Health & Safety file as a minimum. A cpy f a draft Getechnical Certificate t be used fr schemes in Wales is included at the end f this guidance (see als sectin 9). 4 Key Stage 1 Initial Review f Prject HD 22/08: Managing Getechnical Risk (DMRB 4.1.2) Implementatin Guidance Wales Issue1, Revisin 1 January

6 Key stage 1 prcedures can be summarised as: Design Organisatin t determine initial Getechnical Classificatin and appint a DGA fr all Getechnical Categry 1, 2 r 3 prjects. DGA t cmplete preliminary Getechnical Risk Register and incrprate int the Statement f Intent (SOI). Where the SOI is cmpleted prir t agreement f a preferred rute alignment the SOI shuld cnsider all ptins. The frmat f the SOI is mandatry and is given in Appendix B f HD22/08. Fr Getechnical Categry 1 schemes the SOI shuld include Annex A (issued with the PSSR fr Getechnical Categry 2 & 3 schemes) and include sufficient infrmatin t justify the scpe f any prpsed grund investigatins. DGA t submit SOI fr review and certificatin by the OOGA appinted by the Welsh Assembly Gvernment. Fllwing agreement f the SOI the OOGA will issue a signed Getechnical Certificate and the DGA can prceed t Key Stage 2. Fllwing submissin f the SOI the OOGA and DGA can develp and agree prject specific prtcls t deal with subsequent reprting and certificatin requirements which shall be recrded in the prject file. Any agreed prject specific prtcls shuld be reviewed at each subsequent Key Stage and fllwing any revisin f the Getechnical Categry. 5 Key Stage 2 Preliminary Certificatin Key Stage 2 prcedures can be summarised as: Getechnical Categry 1 prjects DGA t cmplete a cmbined PSSR and GIR incrprating an updated Getechnical Risk Register and submit t the OOGA fr review and certificatin. Where the cmbined reprt is cmpleted prir t agreement f a preferred rute all rute ptins under cnsideratin shuld be addressed. Getechnical Categry t be reviewed fllwing assessment f newly acquired getechnical data and/r revisin f the scheme design. The preferred frmats f the PSSR and GIR are given in Appendix C and D respectively f HD22/08. Fllwing agreement f the cmbined reprt the OOGA will issue a signed Getechnical Certificate and then the DGA can prceed t Key Stage 3. Getechnical Categry 2 and 3 prjects DGA t cmplete the PSSR incrprating an updated Getechnical Risk Register and issue t the OOGA fr review and certificatin. Where the PSSR is cmpleted prir t agreement f a preferred rute the PSSR shuld include all rute ptins under cnsideratin. Getechnical Categry t be reviewed fllwing assessment f newly acquired getechnical data and/r revisin f the scheme design. The preferred frmat f the PSSR is given in Appendix C f HD22/08. Annex A t the PSSR shuld be cmpleted detailing prpsed grund investigatins. Fllwing agreement f the PSSR the OOGA will issue a signed Getechnical Certificate and then the DGA can prceed t prcurement and cmpletin f the agreed grund investigatin. Prcurement and specificatin shuld cnfrm t the requirements f the Manual f Cntract Dcuments fr Highway Wrks Vl 5 Sectin 3. DGA t cmplete the GIR incrprating an updated Getechnical Risk Register and issue t the OOGA fr review and certificatin. Getechnical Categry t be reviewed fllwing assessment f newly acquired getechnical data and/r revisin f the scheme design. The frmat f the GIR is given in Appendix D f HD22/08. Fllwing agreement f the GIR the OOGA will issue a signed Getechnical Certificate and then the DGA can prceed t Key Stage 3. 6 Key Stage 3 Getechnical Design and Cnstructin Certificatin Key Stage 3 prcedures can be summarised as: Getechnical Categry 1, 2 and 3 prjects HD 22/08: Managing Getechnical Risk (DMRB 4.1.2) Implementatin Guidance Wales Issue1, Revisin 1 January

7 DGA t cmplete the GDR incrprating an updated Getechnical Risk Register (including assessment f getechnical risks assciated with ptential temprary wrks ptins) and issue t the OOGA fr review and certificatin. Getechnical Categry t be reviewed fllwing assessment f newly acquired getechnical data and/r revisin f the scheme design. The frmat f the GDR is given in Appendix E f HD22/08. Fllwing agreement f the GDR the OOGA will issue a signed Getechnical Certificate and then the scheme can prgress t cnstructin. Sectinal certificatin f the GDR t permit cnstructin t cmmence n apprved elements is acceptable. The GDR shall be prvided t the Overseeing Organisatins Site Nminee (OOSN) fr guidance. Shuld there be a need fr additinal grund investigatins t be carried ut during the curse f a main wrks cntract; r if the design is amended frm that cntained in the certified GDR, then this additinal/ amended wrk shall be subject t Getechnical Certificatin as detailed abve cmmencing with a re-issue and certificatin f Annex A f the PSSR. The DGA and OOGA shuld be prvided with an pprtunity t review and cmment upn the Cntractrs temprary wrks design prir t cnstructin. 7 Key Stage 4 Getechnical Feedback Key Stage 4 prcedures can be summarised as: Getechnical Categry 1, 2 and 3 prjects The Getechnical Feedback Reprt (GFR) shall be cmpleted by the Designer s Site Staff in assciatin with the DGA (wh will need t apprve and certify the reprt) and shall be submitted t the OOGA fr review within 6 mnths f prject cmpletin. The frmat f the GFR is given in Appendix F f HD22/08. It will be the DGA s respnsibility t ensure that the Designer s Site Staff are fully briefed as t the data required t cmplete the GFR. A reduced scpe GFR is apprpriate fr Getechnical Categry 1 schemes and can be agreed with the OOGA. The GFR shuld be prduced as an independent dcument, but nce accepted by the OOGA shuld be incrprated within the Health and Safety File prduced fr the scheme. As built drawings shuld be suitable fr electrnic strage with all drawings and plans scalable frm the digital versin. During the curse f the cnstructin prcess, any significant differences between the actual cnditins fund and thse expected are t be reprted frmally in writing by the Designer t the OOSN, wh in turn shall reprt them t the Overseeing Organisatin withut delay. The cnsequences f these differences shall be reprted in the GFR. 8 CDM Regulatins The reprts prduced as part f the Getechnical Certificatin prcess can be used t fulfil the requirements f the CDM regulatins as they shall dcument the residual prject Health and Safety risks and the methds emplyed t avid, reduce and cntrl these. The reprts shall be included in any tender dcumentatin and the pre-cnstructin infrmatin and cnstructin phase plan. They shall subsequently frm part f the Health and Safety File. Where reprts are cmpleted prir t agreement f a preferred rute they shuld include all rute ptins under cnsideratin including an updated Getechnical Risk Register; in which the risks f the primary hazards are assessed, the cnsequences f these risks t the prject determined, and details f hw the risks are t be managed given. CDM implicatins shuld be highlighted. 9 Csts and respnsibilities All csts fr cmpliance with HD22/08 shuld be surced frm prject funds with third parties being respnsible fr funding this element f their wn prjects. Nte that 3rd party installatins beneath mtrways and trunk rads require a Sectin 61 agreement under the New Rads and Street Wrks Act (NRSWA). This ensures that all the cst f certificatin is brne by the third party. HD 22/08: Managing Getechnical Risk (DMRB 4.1.2) Implementatin Guidance Wales Issue1, Revisin 1 January

8 10 Cmpliance checking All submissins by the DGA fr certificatin shuld first be reviewed by the apprpriate prject manager prir t passing t the OOGA. An additinal Cmpliance Checking sectin has been added t the Getechnical Certificate as detailed in the draft certificate cntained at the end f this guidance, On review f each submissin the PM shuld sign this certificate t cnfirm acceptance f respnsibility fr the submissin being cmpleted in accrdance with HD22/ Dispute reslutin Effective management f getechnical risks and the assciated reprting and certificatin requirements f HD22/08 require the develpment f gd and pragmatic wrking relatinships between the OOGA and the DGA. Shuld there be a cnflict with the tw named parties this shuld be dealt with by escalatin within the tw emplying rganisatins. Ultimately the decisin f the OOGA wh is acting fr the Overseeing Organisatin is final thugh at n stage shuld the OOGA take n any design respnsibility which must remain with the DGA. Issues shuld nly be escalated t the Overseeing Organisatin t cnfirm its tlerance t risk t ensure that the risks are mitigated t an acceptable level and that design slutins d nt incrprate excessive cst. HD 22/08: Managing Getechnical Risk (DMRB 4.1.2) Implementatin Guidance Wales Issue1, Revisin 1 January

9 DMRB Vlume 4 Sectin1 Part 1 HD 22/08 Getechnical Certificate GEOTECHNICAL CERTIFICATE Getechnical Certificate Scheme Title Getechnical Certificate (* Delete as Apprpriate) Certificate Seq. N.. GEOTECHNICAL CERTIFICATE Frm f Certificate t be used by the Designer fr certifying the design f getechnical wrks 1. We certify that the Reprts*, Design Data*, Drawings* r Dcuments* fr the Getechnical Activities listed belw have been prepared by us with reasnable prfessinal skill, care and diligence, and that in ur pinin: i. cnstitute an adequate and ecnmic design fr the prject ii. slutins t all the reasnably freseeable getechnical risks have been incrprated iii. the wrk intended is accurately represented and cnfrms t the Emplyers*/Client s* requirements iv. with the exceptin f any item listed belw r appended verleaf, the dcumentatin has been prepared in accrdance with the relevant standards frm the design Manual fr Rads and Bridges and the Manual f Cntract Dcuments fr Highway Wrks. *where the certificate is accmpanying revisin t design data already certified the fllwing statement shall als be included* v. *the design elements cvered by this certificate are nt detrimental t the design elements previusly certified and nt amended by this certificate* 2. LIST OF REPORTS, DESIGN DATA, DRAWINGS OR DOCUMENTS 3. DEPARTURES FROM STANDARDS List f any departures frm relevant standards if nne write nne 1 f 2

10 DMRB Vlume 4 Sectin1 Getechnical Certificate Part 1 HD 22/08 4. INCORPORATION OF GEOTECHNICAL DATA INTO CONSTRUCTION DETAILS *where the certificate is accmpanying final design data the fllwing statement shall als be included* * The Reprts, Design Data Drawings r Dcuments listed in 2 abve have been accurately translated nt the cnstructin drawings r ther designs dcuments bearing the unique numbers listed belw/appended verleaf.* Signed: Designer (Designer Getechnical Advisr) Name: Date:.. On behalf f... *Signed:. *Cntractr (1) (Agent r Cntracts Directr) *Name:.. *Date:.. *On behalf f... (1) Fr Cntractr read als all Third Parties respnsible fr the wrks (e.g. utility cmpany, statutry undertaker r develper with apprpriate planning cnsent). 5. COMPLIANCE CHECK. I am satisfied that the submitted dcuments detailed in sectin 2: i. have been cmpleted in line with the requirements f HD22/08 ii. incrprate apprved design prpsals/ptins; and iii. are acceptable fr submissin t the Overseeing Organisatins Getechnical Advisr fr review and certificatin. Signed:.. * Welsh Assembly Gvernment, Rads and Prjects Divisin * Trunk Rad Agency * Traffic Wales Name:... Rle:... Date:... This Certificate is: (a) received*(see nte) (b) received with cmments as fllws:* (see nte) (c) returned marked cmments as fllws:* (see nte) Signed:... Overseeing Organisatin Getechnical Advisr Name:... On behalf f:.... Date:... Nte: RECEIVED = SUBMISSION ACCOMPANYING CERIFICATE IS ACCEPTED. RECEIVED WITH COMMENTS = SUBMISSION ACCOMPANYING CERTIFICATE GENERALLY ACCEPTABLE BUT REQUIRE MINOR AMENDMENT WHICH CAN BE ADDRESSED IN SUBSEQUENT REVISIONS. RECEIVED MARKED COMMENTS = SUBMISSION ACCOMPANYING CERTIFICATE UNACCEPTABLE AND SHOULD BE REVISED AND RESUBMITTED. 2 f 2