CONSTRUCTION SAFETY EXECUTION PLAN

Project Name: Location of Work: Brief Description of Work: Subcontractor Name: Planned Start Date: Planned Completion Date: Date:

Plan Submitted By: David A Smith

PLAN CONTENTS CHECKLIST

Included N/A

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Project Key Personnel and Emergency Contact List Contractor's Basic Safety Information Page Competent Persons List Contractor's Summary Construction Schedule (One Page) Pre-Construction Jobsite Safety Inspection Form Construction Execution Plan Document Safety Procedures and Plans Safety & Reliability Plan for Working around Operating Equipment Request for Items Requiring Special Approval

PLAN REVIEW & APPROVAL

Client : ______________________________________________________Date: ______________________

Berry Y&V Project Manager: ______________________________ Date: ____________________ Berry Y&V HSE&S Director: ______________________________________ Date: _____________ Project HSE: ________________________________________ Date: _____________________
After last person reviews and sign-offs on plan make copies and distribute to all signatories.

CONSTRUCTION SAFETY EXECUTION PLAN

PROJECT KEY PERSONNEL AND EMERGENCY CONTACT LIST

Contractor's Key Personnel

Position/Title Project Manager Name Work Phone Home Phone Pager/Cell Fax

Construction Manager

Craft Superintendents

HSE Manager

Admin Assistant

CLIENT Key Personnel

Position/Title Project Manger Name Work Phone Home Phone Pager/Cell Fax

Project Engineer

Project HSE

CONSTRUCTION SAFETY EXECUTION PLAN

______ ______
Project Name Contractor's Name

EMERGENCY INFORMATION
Resource Needed Name of Resource Telephone Number

Medical
Site Medical Facility Ambulance Designated Physician Address Hospital Address

______________________________________________
_________________________________________________________ _________________________________________________________ _________________________________________________________ _________________________________________________________ _________________________________________________________ _________________________________________________________

Fire or Release
Fire Department _________________________________________________________

HSE Incident
Berry Y&V HSE Client Contact _________________________________________________________ _________________________________________________________

Evacuation Plan When an evacuation is necessary Berry Y&V will verify that all confined spaces are clear, shut down all equipment in an orderly manner, report to the assembly areas and check in with their supervisor. Each supervisor will take a roll call and account for everyone on his or her crew. Each supervisor will report to BYV HSE or Project Management as to the accountability of his or her crew. BYV personnel will remain at the assembly area in an orderly fashion and wait for further instructions from BYV or Client HSE or Emergency Response representative. All telephone contact will be kept to a minimum as to prevent interference with Emergency Responders. All vehicles will pull over, with keys remaining in the ignition and proceed to the assembly area to check in. Once there they will make an effort to check-in with appropriate supervision, and report the information needed to be accounted for.

CONSTRUCTION SAFETY EXECUTION PLAN

COMPETENT PERSONS LIST

Project Name

Contractor's Name

After review of formal training received and on-the-job experience, the Contractor has named the following personnel as the Competent Persons for this project.
Expertise Cranes Fork Lifts Equipment Electrical X-Ray Ladders Fall Protection Rigging Steel Erection Welding, Cutting & Grinding Hot Taps Excavations Scaffolding Name Job Title

Copies of this List will be posted at the worksite so all workers understand who the Competent Persons are.

CONSTRUCTION SAFETY EXECUTION PLAN

PRE-CONSTRUCTION JOBSITE SAFETY INSPECTION FORM This form is used to walk down areas where Construction will be taking place in the near future. The purpose of the walk down is to: y Identify any existing hazards so that they can be eliminated before the work crews move in. y Identify work areas hazards so they can be addressed in the Construction Execution Plan Document. y Develop a Logistics Plan for the Work Area, Material Storage, Fab Area, etc. Project: Area Being Inspected: Jobsite
Inspected by: HSE Manager Construction Manager Superintendent(s)

Date Inspected: Projected Field Start Date:

Potential Hazard
Uneven/Slick Walking Surface Climbing Hazards (not Burns) Hoses (water, air, N2, steam,etc) Temporary piping Electrical Cords Dismantled Equipment / Piping Tools and Equipment Old Scaffolding Trash Bins / Barrels Full Sheet Metal / Steel / Wire Boards and Nails Water and Algae Oil Leaks and Spills Discarded Nuts, Bolts, Gaskets Electrical Scrap Miscellaneous Trash Safety Showers in need of repair

PASS

FAIL

Potential Hazard

PASS

FAIL

Potential Falling Objects Unsecured Equipment / Piping Trash on Platforms / Structures General Appearance Valve Wrenches laying around Cut / Puncture Hazard Pinch Points Platform / Structure Damaged Lighting Inadequate Hot Lines / Equipment Uninsulated Loose Insulation Process Leak(steam,product,etc) Broken Concrete Fire Fighting Equip Inoperable Access Road in need of repair Warning Signs in need of repair Eye Wash Stations need repair Other (Explain Below) Any items marked in the FAIL column require an explanation below.

Describe Problem(s) Found

Action Req By

CONSTRUCTION SAFETY EXECUTION PLAN

CONSTRUCTION EXECUTION PLAN DOCUMENT This section contains the detailed written plans of how the job will be completed. It encompasses Safety, Schedule, and Scope of Work, Hazards involved in the job and Mitigation Strategies for those hazards. This section uses five (5) main key points to help you plan your work.

1. WHAT IS THE WORK REQUIRED TO COMPLETE THIS PROJECT?

Location of the Project (Site, Unit, etc): How long will it take to complete the Job? List the work scope that will be required to complete the Project (Include a list of tasks required, in sequential order, to complete the project from start to finish. Add additional lines/pages as required to fully explain work scope):

Berry Y&V scope of work is as follows:

1. 2. 3. 4. 5. 6. 7. 8. Mobilize equipment and personnel to Facility Attend all required trainings Prepare for material arrivals and secure lay down areas Prepare for abatement of possible lead, TSA or asbestos materials according toClient Specifications Install new foundations, steel and supports as defined by contract Install vessels, pumps, miscellaneous piping and equipment, according to contract requirements Conduct all required testing such as hydro, x-ray, in-service, UT, etc. Prepare system packages including all documentation for start-up and or turnover

2. HOW WILL THE JOB/TASK BE PERFORMED?

How will the tasks detailed in #1 be performed? What procedures will be used? What applicable Client Safety Standards are applicable to these specific tasks? Add additional lines/pages as needed. Task Mobilize personnel and trailers Mobilize equipment and materials Materials to work locations (Steel or Pipe) Fireboxes Steel or Pipe Welding Hydro Equipment Setting Entering Equipment Demobilization How Performed Trailers will be mobilized to proper location with haul trucks and the use of flagman. Personnel will park in area as directed. Equipment will be mobilized to the proper locations with haul trucks and use of flagman. Materials will be unloaded with a forklift and pickers, staged neatly and barricaded. Materials to be trailered from laydown area to work site, off loaded and neatly stored at site. Areas will be cleaned daily. Enclose hot work area with fire blanket to contain sparks as necessary. Will be put in place by the use of cranes and pickers. The use of flagman and qualified riggers will fly materials. Steel will be plumbed and level, signed off by QA/QC before grouting. Once grouted, pipe shall start erecting pipe spools. Fireboxes will be complete, material inside the fireboxes, welding machines grounded, firewatch, fire extinguisher, vest, and horn, as appropriate. Lines will be signed off with pre-walked papers before hydros. Fill lines, pressure to the test pressure designed per system, drain line water to safe location at grade. Logistics to site to be preplanned by rigging and subcontractor. Plan to be agreed upon by HSE Manager and Construction Manager. Work to be done inside equipment will be done according to applicable Regulations & BYV procedures. Qualified and trained people will be used in this work. Remove leftover pipe, steel, and trash. Have power and water from trailers disconnected. Remove trailers.

Unloading steel and piping

Survey load on trailer to ensure safe material handling. Guide truck and trailer to unloading area. Truck driver is the only one to remove chains, binder straps, etc. Pipe loads will be required to have standards on trailers to prevent pipe roll off. Spotter will be needed to lay out timbers with a fork lift and on the trailer to ensure good point of contact with load and forks. Designated flagman for fork lifts and cranes. Clear swing path. Personnel on trailer to move out of swing path or descend trailer in a safe manner. Stairs/handrails on truck ladder. Survey load on trailer to ensure safe material handling. Guide truck and trailer to unloading area. Truck driver is the only one to remove chains, binder straps, etc. Pipe loads will be required to have standards on trailers to prevent pipe roll off. Spotter will be needed to lay out timbers with a fork lift and on the trailer to ensure good point of contact with load and forks. Designated flagman for fork lifts and cranes. Clear swing path. Personnel on trailer to move out of swing path or descend trailer in a safe manner. Stairs/handrails on truck ladder. Size crane to each mechanical item to be set. Prep ground (surface mat if needed). Barricade working area. Set crane up level and stable. Attach predetermined sized slings and shackles at specified locations on equipment. Attach tag lines. Pick load up in a safe manner. Swing load to the intended location. Lower load slowly onto the anchor bolts. Line equipment up and lower load completely down. Unhook rigging. Remove crane. Clean up work area.

Loading steel and piping

Setting mechanical equipment

3. WHAT WILL BE USED TO PERFORM THE JOB/TASK?

List Tools, Equipment, Materials and Personnel that will be required/used to complete the project How many personnel are needed to complete this project? _________________________ What skills / craft level must they have? Construction Manager, HSE Manager, Planner/Cost Tracker, QA/QC, Welders (certified), Pipe fitters (skill tested), Ironworkers (skill tested), Equipment Operators(certified), Concrete Workers, Firewatch/Attendants (skill tested), Carpenters(skill tested), Scaffold Builders(skill tested) What Materials will be needed at the jobsite?

Pipe Valves Gaskets Studs & Nuts Structural Steel

E&I Materials Scaffold Materials Paint Hilti Bolts Hilti Epoxy

Pipe Cradles Blinds Welding Gases Welding Rods Concrete Materials

Carpentry Materials Grout Insulation Materials

Are any of the materials special orders or require a long lead time? What Tools will be needed at the jobsite?

Fully Stocked Tool Trailer Misc. Hand Tools

Chain Falls Assorted Consumables

Come-A-Longs

What Equipment will be needed at the jobsite?

Trucks Rigging Equipment Tool Trailers Cranes Forklifts

Welding Machines Hydro Test Pumps Man-lifts Air Compressors Small Hand Tools

Scaffolding

Does any of the Equipment require special ordering or reserving to ensure availability?

4. WHAT COULD HAPPEN WHEN PERFORMING THE TASK AND WHY?

Task Working from scaffolds What could happen to cause an incident or injury? Fall, scaffold collapse, falling objects Bolt ups Eye injury, pinch points, excessive noise, ruptured air hose Grinding Excessive noise, airborne particulates, electrical shock kick-backs, damaged Grinding wheels Damaged rigging, exceeding rigging capacity, improper rigging Swinging material from staging area to work area Working from Manlifts Improper Operation , pinch points, fall hazard, congested area Exiting and entering Manlift basket onto structure Welding Fire potential, damaged leads, electrical shock, arc flashes, excessive heat Cutting with torch Fire potential, ruptured hoses, eye injury, excessive heat Hydrostatic testing Lines not isolated, exceed pressure test level, line rupture, gasket failure High/Low Voltage Unanticipated contact, electrical shock, equipment damage

Securing material to crane

Operator blind spot, suspended loads, control of load, pinch points

Fall hazard

5. WHAT WILL BE DONE TO PREVENT THE POTENTIAL INCIDENTS IDENTIFIED IN #4 ABOVE?

Incident That Could Occur Fall, scaffold collapse, falling objects What will be done to prevent it from happening Wear harnesses W/lifeline, scaffold will be erected and inspected by a competent person to applicable standards and inspection tag will be updated by a worker trained in scaffold user inspections on a per shift basis, barricade under work areas, secure tools or place in bolt bag when not in use Sealed eyewear and faceshield while using impact, leather gloves, keep hands from between socket, flanges & structure, double hearing protection, if using drive impact or larger, use proper size retaining rings, inspect tools before each use, keep hoses away from pinch points and sharp edges Proper hearing protection, sealed eye wear with a faceshield, use GFCI at the source of power Inspect chokers & shackles prior to use, assure rigging is rated for the weight of the load, use competent riggers Stay in radio or visual communication with operator at all times, barricade around lift & swing area, operator to sound audible warning during lift and swing, lift and swing path to be kept clear of all personnel, use tag line of sufficient length to control load, keep body parts from between structure and material Use qualified & competent operators, keep body parts inside Manlifts, 100% tie off to inside of basket, communicate with all personnel in area when moving Manlifts, use spotter if necessary, barricade under work area Two people will go up in Manlift, operator will stay in basket, employee will tie off to a proper anchorage point outside of the basket before leaving basket then untie from basket. Employee will reverse action to get back to basket. Contain sparks, keep area free of combustible materials, position welding machines & leads out of harms way, inspect tools prior to use, ground as close to work as possible, ensure equipment is grounded, make sure power lines are shielded, use spotters when in close proximity, use O2/LEL Meters and Firewatch as required by permits. Contain sparks, keep area free of combustible materials, position hoses, O2 and acetylene bottles away from falling sparks, inspect hoses prior to use, wear burning goggles or shaded faceshield while cutting with torch. Verify valves are seated completely closed, remove all non-essential personnel from area, verify pressure rating prior to test, inspect all connections prior to pressuring, install barricade, lines will be depressurized before any bolts, or plugs will be tightened.

Eye injury, pinch points, excessive noise, ruptured air hose

Excessive noise, airborne particulates, electrical shock Damaged rigging, exceeding rigging capacity, improper rigging

Operator blind spot, suspended loads, control of load, pinch points

Operating Manlifts, pinch points, fall hazard, congested area

Fall hazard

Fire potential, damaged leads, electrical shock

Fire potential, ruptured hoses, eye injury

Lines not isolated, exceed pressure test level, line rupture

Moving equipment Use certified operators, spotter

CONSTRUCTION SAFETY EXECUTION PLAN

SAFETY PROCEDURES AND PLANS y

Injury and Incident Reporting and Documentation - Procedures that will be used to report injuries and
non-injury incidents:

Severe Weather Plan - Ensure workers are not in danger due to weather conditions. Include procedures for
when work will be stopped/resumed:

Heat and Cold Stress Plans - Provide a job specific heat/cold stress plans. Include plans for mitigating both: JSA Process - How Berry Y&V will train workers and implement the JSA Process :

Safety Meeting Schedule - List the daily and scheduled safety meetings and times:

Housekeeping Plan - Describe our standard of housekeeping and how it will be managed on a continuous
basis:

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Injury/Incident Reporting and Documentation:

Non-Injury Incidents (Near Miss) Personnel will follow the procedures outlined in the reporting of any non-injury incidents that could occur while working is this facility. This also includes any of our sub-contractors. The Berry Y&V HSE Manager, Craft Supervisor, & Contract Safety will investigate Near Misses, and generate site incident reports before end of shift. Minor Injury/Illness (On Site Treatment) The First Aid Facility will be used for all non-emergency treatments. All personnel will notify Project Safety Specialists immediately. Berry Y&V or Contractor Safety Representative will always escort the injured/ill employee to the First Aid Facility for treatment. The first aid attendant will fill out the Medical portion of the Safety Incident report. Berry Y&V Management, Craft Supervisor & Contract Safety will investigate the Injury/Illness, and generate site incident report within 24 hours. Berry Y&V will review and update the report and ensure employee affected has all after-hours contact numbers in his/her hand, and is refreshed on proper protocol before leaving for the day, should problems arise after hours. Injury/Illness (Requiring Offsite Medical Treatment) Before leaving the site, the First Aid Facility should be visited for an initial assessment, to initiate the Safety Incident report and to pick up a Contractor Personal Injury/Illness Report Form. Berry Y&V and appropriate Project Management personnel will be immediately notified. An HSE representative will accompany the injured/ill employee offsite. A Medical Status Report report will be completed by a physician. Berry Y&V Management will investigate the Injury/Illness, and generate site incident report by the end of the shift on the day of the injury/illness. A copy of the Job Safety Analysis (JSA) in use during the time of the incident will be attached to the incident investigation. Within 24 hours Berry Y&V will provide copies of the Employers First Report of Injury/Illness and other reports as required. Berry Y&V will ensure affected employee has all contact numbers in his/her hand, and is refreshed on proper protocol before leaving for the day, should problems arise after hours.

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SEVERE WEATHER PLAN (See Corporate Procedure 300.27 Severe Weather)

DEFINITIONS (SEVERE WEATHER) Lightning: All large-scale, high tension, natural, electrical discharge in the atmosphere; the visible flash of light accompanying such discharge. High Winds and Rain: When the winds or rain become a hazard to the work force or the work being performed. Wind approximately 30 mph and rain limiting visibility or footing. RESPONSIBILITIES y y y Berry Y&V HSE Manager will keep Construction Manager updated as to location & intensity of storms. Berry Y&V will determine when lightning is threatening imminent danger. Berry Y&V Site Manager will make the call as to when all rain-outs are determined.

Severe Weather Responsibilities Lighting y y y y y Avoid exposing personnel at high elevations, such as on structural steel members, pipe-racks, roof tops, process columns, antennas, etc. Make sure that personnel do not group together and/or huddle under or near tall structures. Avoid a depression with standing or running water or a ditch. Have all crane booms lowered to the ground or retracted to the shortest boom length. All cranes, derricks, gin poles, and erection rigs unable to be boomed down must be grounded.

High Winds and/or Rain When high wind creates a hazard to craftsmen or work being performed (e.g., instability in elevated areas, limited visibility due to dust or particles in the air, unmanageable materials, etc.) supervision will stop work activities, re-assign work and area, properly store and secure material which might blow away, injure or damage, lower/tie down crane booms and obtain further instruction from Site Management. When rain creates a hazard to craftsman on work being performed (e.g., un-stable footing conditions due to slippery structural steel, muddy and flooded work environments, unstable trenches or excavations, poor visibility due to hazard, reassign work duties and/or areas, and obtain further instructions from Project Management Appropriate material should be available and stored on the project to facilitate the securing of project property, materials, and equipment, e.g., rope, wire, and boards/plywood.

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Heat Stress and Cold Stress Plans OVER VIEW

Berry Y&V is concerned about the health and well being of all employees. Berry Y&V Management is committed to making sure employees are trained to recognize the symptoms of Heat Stress and have knowledge on how to protect themselves from the hazards associated with the causes of High Heat Conditions that cause Heat Stress Disorders. See Corporate Procedure 300.22 Heat Stress. See Corporate Procedure 300.23 Cold Stress.

PURPOSE
The purpose of this plan is to assure that our employees are well informed about the hazard of High Heat/Cold conditions and to provide information and training on engineering, administrative and PPE controls. We understand that employees will sometimes be exposed to working in a hot/cold environment, and they may be required to work for extended periods of time in the hot/cold environment, therefore we feel this policy is necessary to avoid hazards to their safety and health.

RESPONSIBILITIES
Management of Berry Y&V will be responsible for providing information to all employees concerning their expectations on how to prevent Heat/Cold Stress Disorders and how our Project Management and our HSE Department will work together to provide means of eliminating as many heat/cold related hazards as possible through the use of appropriate Health Hazard control.

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HAZARD CONTROLS
A. Engineering Controls y Will ensure that all areas have proper and adequate ventilation and or insulation y Will provide other sources of cooling/heating methods in extreme environments y Will make arrangements for frequent breaks B. Administrative Controls y y y y y Will provide heat/cold stress training to all employees Will provide an adequate and sanitary drinking facility and drinking apparatus Will provide a method to rotate employees frequently during extreme conditions Will base decisions on Heat/Cold Index NOT Ambient temperature Will utilize the Brothers Keeper mentality and watch for any signs or symptoms

C. Protective Equipment y y y Will provide appropriate PPE Will Provide frequent breaks Will provide Cool Down/Warm UP areas

Safety Problems in Extreme Environments

These are the things that could be the cause of an accident if proper preventive methods are not applied. Time and consideration must be taken to recognize a safe and effective method to work under these conditions.

EMPLOYEE AWARENESS
Berry Y&V feels that educating our employees about extreme environmental conditions is the key method of preventing Heat/Cold Stress Disorders. The benefit of this will help to eliminate safety hazards associated with working in hot/cold areas. Our Management and our Safety Representatives will continuously communicate the importance of using good safe techniques to prevent Heat/Cold Stress. We will also monitor and make special provisions for employees taking medications. We will continue to recommend to all employees that they absorb enough daily fluids (water or thirst quencher) to prevent dehydration. We will also expect each employee to look out for others around them and communicate as soon as possible whenever signs of Heat or Cold Stress occur. This philosophy is known as the Brothers Keeper mentality.

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JSA Process
Explanation of the JSA Process will be communicated to all employees during site specific training. A competent member of a team working on a task will complete a JSA. All crew members will then sign on the JSA only after becoming familiar of every aspect of the document. The JSA will be maintained at the job site. Upon completion of task or end of shift the JSA will be returned to foreman for review and signed off. The foreman will submit the JSA to the Berry Y&V HSE Manager for final review and storage.

Safety Meeting Schedule

The need for regular safety meetings on the job cannot be stressed too highly. An all hands Safety Meeting will be conducted by Berry Y&V on specified days at the start of the shift. This will be conducted by Berry Y&V Management and/or Supervisors. The meeting is opened to all employees for comments or concerns. Each foreman will be required to hold a daily safety meeting (toolbox). He will review the hazards that the employees might encounter during that shift and review the JSA for the tasks they are assigned to. The Berry Y&V HSE Manager shall prepare discussion outlines that are relevant to the work site, work areas, exposures and occurrences for use by the presenters. Documentation of the meeting agenda, information reviewed, comments and attendees shall be maintained and provided to the Berry Y&V HSE Manager upon request.

Housekeeping Plan
Combustible materials, such as, oil, Paints, paint thinners, lacquers, other flammable materials such as oil soaked rags, waste and shavings, must be kept in metal containers with self closing lids in an area far removed from any other flammable materials. All containers should be emptied as soon as possible. Paper and other combustible materials will not be allowed to accumulate. Weeds and other vegetation should not be permitted to grow near and around Company property, buildings or other structures. All solvents and flammable liquids must be kept in approved and properly labeled containers. Rubbish should be placed in a suitable container for waste disposal. Be sure that you are aware of the character of any waste material or rubbish and ensure that it is placed in the correct container for that particular type. No rubbish or waste material may be burned in the facility. All work areas and walkways will be kept clear of tripping hazards at all times. Hoses, cords, and leads must be maintained as to prevent tripping hazards. Berry Y&V HSE Personnel with members of the work force will conduct Daily Walks and they will be looking for deficiencies in this particular area as well as other hazards. Housekeeping is everyones responsibility.

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CONSTRUCTION SAFETY EXECUTION PLAN

REQUEST FOR ITEMS REQUIRING SPECIAL APPROVAL Safety and security regulations at Client Sites require review and approval for certain items or actions. To minimize delays to your construction crews this section highlights some of those items requiring approval and provides you with an opportunity to plan for them before construction starts. Completion of the questions and information below will enable your Berry Y&V construction contacts to provide you with specific forms, requirements and time needed to get approval for these items:

Vehicle Entry into Plants

All sites require review and approval of cars and trucks that will be brought on site. Your company logo must be displayed on both sides of the vehicle. The number of vehicles allowed in is limited and is based on business needs and use of the vehicle while in plant. Do you plan on bringing vehicles into the plant? _________ How many? _____ What will they be used for? ___________________________________________

Office Trailers, Buildings, Conexes

All office trailers and temporary buildings must meet certain design, location and housing criteria. Approval from the Client is required. Do you plan on setting up office trailers or conexes in the plant? _________ How many? ____ What are you planning on setting up? What utilities do they need? What will they be used for?

Road Blockages or Closures

Any road closures or blockages require review and approval from Berry Y&V and Client Supervision. Do you plan on having to block any roads to complete the construction? Why does the road need to be blocked? Which roads? Starting approximately when? Lasting for how long?

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CONSTRUCTION SAFETY EXECUTION PLAN

REQUEST FOR ITEMS REQUIRING SPECIAL APPROVAL (CONTINUED)

Cranes, Manlifts, Scissors Lifts

All cranes, manlifts, scissors lifts must be inspected by a competent person before they can be used on the Client Site. Do you plan on bringing in any cranes or lifts? List the type/make/description and when you plan to bring them onto the Site

MSDS for Chemicals and Hazardous Materials

MSDS sheets for all chemicals and hazardous materials must be reviewed and approved by Berry Y&V/Client Department before being brought into the Site. List them below and provide a copy of the MSDS sheets for review: Chemical What will it be used for?

All chemicals are listed in binders kept in HSE Managers Office y

All pertinent chemicals as are necessary for a basic construction job.

Deviations to Client Rules and Policies

Any waivers or deviations to Berry Y&V and Client standards, rules and policies must be reviewed and approved before construction start. Do you plan on asking for any waivers or deviations? __________ if yes, provide details under separate cover.

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