IR 05000263/2022013

From kanterella
Jump to navigation Jump to search
Biennial Problem Identification and Resolution Inspection Report 05000263/2022013
ML22325A226
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 11/21/2022
From: Laura Kozak
NRC/RGN-III/DORS/RPB3
To: Domingos C
Northern States Power Company, Minnesota
References
IR 2022013
Download: ML22325A226 (1)


Text

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000263/2022013

Dear Mr. Domingos:

On October 17, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Monticello Nuclear Generating Plant and discussed the results of this inspection with Mr. S. Hafen, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

No findings or violations of more than minor significance were identified during this inspection.

November 21, 2022 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Laura L. Kozak, Acting Chief Reactor Projects Branch 3 Division of Operating Reactor Safety Docket No. 05000263 License No. DPR-22

Enclosure:

As stated

Inspection Report

Docket Number:

05000263

License Number:

DPR-22

Report Number:

05000263/2022013

Enterprise Identifier:

I-2022-013-0008

Licensee:

Northern States Power Company, Minnesota

Facility:

Monticello Nuclear Generating Plant

Location:

Monticello, MN

Inspection Dates:

September 26, 2022 to October 14, 2022

Inspectors:

L. Haeg, Project Manager

R. Ng, Senior Project Engineer

C. Norton, Senior Resident Inspector

J. Robbins, Operations Engineer

Approved By:

Laura L. Kozak, Acting Chief

Reactor Projects Branch 3

Division of Operating Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Monticello Nuclear Generating Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)

(1) The inspectors performed a biennial assessment of the effectiveness of the licensees problem identification and resolution program, use of operating experience, self-assessments and audits, and safety-conscious work environment.

Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees problem identification and resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a 5-year review of the reactor water cleanup system.

Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.

Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.

Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B Based on the samples reviewed, the team concluded that the licensee's implementation of the Corrective Action Program was generally effective and supported nuclear safety.

Effectiveness of Problem Identification:

Based on the samples reviewed, the team determined that the licensee continued to identify issues at a low threshold and appropriately entered these issues into the Corrective Action Program. The team also determined that the licensee usually entered problems into the Corrective Action Program completely and accurately.

The team noted that issues were being identified by all levels of organization and with varying degrees of safety significance. The licensee also utilized a number of Corrective Action Program support processes to identify problems, including the self-assessment and audit process and the Operating Experience Program. Some deficiencies were identified by external organizations that had not been previously identified by licensee staff and were subsequently entered into the Corrective Action Program for resolution. For example, the licensee performed departmental self-assessments and Nuclear Oversight audits to identify issues in station processes. The identified deficiencies and improvement opportunities were entered into the Corrective Action Program for resolution. Similarly, the licensee screened issues from both NRC and industry operating experience and entered them into the Corrective Action Program when they were applicable to the station.

As low level, as well as safety significant issues were entered into the CAP, the team determined that the licensee was generally effective at identifying trends and taking appropriate corrective actions to prevent more significant problems from developing. In addition, the licensee used the Corrective Action Program to document instances in which previous corrective actions were ineffective or were inappropriately closed.

The team performed a 5-year review of the reactor water cleanup system. Specifically, the team focused on any recurring or age-related issues of the system. As part of this review, the team interviewed the system engineer, reviewed plant health reports, and selected corrective action and condition evaluation documents. In addition, the team performed a partial system walkdown to assess the material condition of the system piping, selected components and surrounding areas. The team concluded that deficiencies and concerns were identified and entered into the Corrective Action Program at a low threshold and the corrective actions were adequate and timely, commensurate with their safety significance.

Effectiveness of Prioritization and Evaluation of Issues:

Based on the samples reviewed, the team determined that licensee performance was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified problem. In general, once a degraded or non-conforming issue was identified, the CAP process was effective in directing equipment operability/functionality review. The licensee pre-screened issues at the site level and then formally dispositioned the issues at the Fleet CAP Screening meeting. During the meetings the team observed, licensee staff were generally thorough and intrusive in reviewing and screening issues. The team also observed healthy dialogue and good interactions among the members of the screening groups. The members came prepared and challenged each other on disposition of the identified conditions. Actions were prioritized based on the safety significance of the issues.

Effectiveness of Corrective Actions:

Based on the samples reviewed, the team determined that the licensee was generally effective in implementing corrective actions. In general, corrective actions for deficiencies that were safety significant were implemented in a timely manner. Problems requiring the performance of a root cause evaluation or other causal evaluation methodologies were resolved in accordance with Corrective Action Program requirements. The team sampled assignments associated with violations that were identified by the NRC previously, and with licensee event reports (LERs). The team determined that the corrective actions sampled were generally effective and timely.

The team noted a few examples of minor process issues with the Corrective Action Program.

For example, following the 2021 refueling outage, a corrective work order tied to a corrective action to enact repairs on an isolation valve was allowed to be cancelled, and a Procedure Change Request (PCR) tied to a corrective action was allowed to be inappropriately postponed beyond the next refueling outage in 2023. Due to other programmatic barriers, this valve would not have been allowed to be tested at an extended frequency against the requirements of Title 10 CFR Part 50, Appendix J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors Program. Also in 2021, following a B severity level event where workers were not signed on to a clearance order, the corrective action to evaluate the process was closed to no action. Because additional actions were taken that were not directly linked to the apparent cause, the condition adverse to quality was corrected.

Lastly, a PCR tied to a corrective action to improve guidance within the fleet valve packing procedure was found to have a lower priority incorrectly assigned. Although this lower priority didnt impact how the PCR would have been handled in the CAP, the inspectors observed that it could have resulted in the corrective action not being taken in a timely manner. These minor process issues are documented here to emphasize the overall importance of effective and timely corrective action. The licensee entered these issues into the Corrective Action Program for evaluation.

Assessment 71152B Based on the samples reviewed, the team determined that licensee's performance in the use of operating experience was generally effective. The licensee screened industry and NRC operating experience information for applicability to station. Based on these initial screenings, the licensee-initiated actions in the Corrective Action Program to fully evaluate the impact, if any, to the station. When applicable, actions were developed and implemented under the Corrective Action Program to prevent similar issues from occurring. Operating experience lessons learned were communicated and incorporated into plant operations. The team observed the information being used in daily activities, such as pre-job briefs, as well as Corrective Action Program issues reviews and investigations. As stated in the Corrective Action Program assessment section, the licensee screened issues as a fleet and as such the use of operating experience was inherent to Corrective Action Program implementation.

Assessment 71152B Based on the samples reviewed, the team determined that the licensee's performance of self-assessments and audits was generally effective. The licensee performed department self-assessments and quality assurance audits throughout the organization on a periodic basis. These self-assessments and audits were generally effective at identifying issues and enhancement opportunities at an appropriate threshold. The self-assessments and audits reviewed by the team identified issues that were not previously known, including issues within the Corrective Action Program itself. Nuclear Oversight (NOS) had identified deficiencies with the licensee's processes and those issues were addressed by the station using the Corrective Action Program.

Assessment 71152B The team assessed the safety-conscious work environment (SCWE) at Monticello Nuclear Generating Plant. The teams conducted individual interviews and facilitated supervisor and worker focus groups. The team also reviewed CAP documents, Nuclear Safety Culture Monitoring Panel reports, the results of Pulse Surveys, and the 2022 Safety Culture Assessment. The team did not identify any SCWE issues. The team concluded that an environment exists at Monticello where personnel were free to raise nuclear safety concerns without fear of retaliation. No issues of concern were identified.

Minor Violation 71152B Minor Violation: During this inspection, the team reviewed the licensee's scaffold program due to a number of issues related to the proximity of scaffolding to safety-related systems, structures, and components.

Licensee fleet procedure FP-MA-FSC-01, Scaffolding, Revision 0, establishes that scaffold placed on top of the torus may be supported from the torus shell as long as a 2-inch clearance is maintained between the scaffold and any permanent structure. The weight of the scaffold and its payload was also required to be less than 750 pounds. Scaffolding attached to, resting on, or supporting safety-related systems or ISFSI important to safety systems required an engineering evaluation and approval from the plant's Operations department.

Further, FP-MA-FSC-01 required that documentation of the scaffold evaluation and approval be retained on form QF1817 in accordance with FP-G-RM-01, Quality Assurance Records Control. During a walkdown of the scaffoldings in the reactor building, the team identified that scaffold 89 was constructed on top of the torus and did not maintain a 2-inch clearance from the reactor building wall. The team questioned the licensee regarding the acceptability of the scaffolding considering those procedural requirements. The licensee was unable to produce form QF1817 for scaffold 89 that detailed the engineering evaluation and approval of the build. On October 4, 2022, the licensee reevaluated and reperformed the scaffold approval for scaffold 89. After determining that the scaffold was acceptable, the licensee documented such on QF1817, under Approval Number 602000009397.

Screening: The inspectors determined the performance deficiency was minor. The inspectors determined that the performance deficiency was minor as it was similar to Appendix E, "Examples of Minor Issues," example 4.a, where a subsequent evaluation determined that there was no safety concern. Specifically, the licensee reperformed the engineering evaluation and determined that the scaffold configuration was acceptable. The licensee entered this issue into the CAP as 501000066951.

Enforcement:

Title 10 CFR Part 50, Appendix B, Criterion XVII, Quality Assurance Records, requires in part that sufficient records shall be maintained to furnish evidence of activities affecting quality and the records shall be identifiable and retrievable.

Contrary to the above, the licensee did not maintain and could not retrieve records to furnish evidence of activities affecting quality. Specifically, the licensee did not maintain and could not retrieve the engineering evaluation that determined the configuration of scaffolding that was attached to a safety-related structure and resting on the torus, a safety-related component, was acceptable.

This failure to comply with 10 CFR 50, Appendix B, Criterion XVII constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On October 14, 2022, the inspectors presented the biennial problem identification and resolution inspection results to Mr. S. Hafen and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

500000313882

Condition Evaluation: Internal Contamination 985 RWPR

10/12/2022

500001474449

XR-27-1 Had Excessive Leakage During Leak Rate Testing

04/14/2015

500001481220

Temperature Rating of Sprinkler Nozzle Appears Incorrect

05/30/2015

500001486523

MOV SSA: Offsite Power Transient Degraded Voltage

Analysis

07/17/2015

500001496761

Potential Non-Conservative Tech Spec for EDG Voltage

10/14/2015

500001517339

EDG Room and Cabinet Temperature Calculation Issues

03/30/2016

500001527265

Elevated Temperature in SBGT Room

07/05/2016

500001547508

CV-1995 Did Not Open on a Shutdown of 12 RHR Pump

01/14/2017

501000001720

External OE: Fermi NCV for TOL Sizing

08/16/2017

501000005677

URI for Blast Analysis14-068

11/20/2017

501000009081

AA NRC Insp Obsv - Vital Area Access

03/02/2018

501000010409

Lower Insoluble Cu Deposition on Fuel

04/20/2018

501000010436

Legacy FW Temperature Input Issue

04/06/2018

501000015104

Snubber C-22 Shows Accelerated Wear

08/02/2018

501000019500

NOS: Fire Doors Not Validated to Tech Eval

03/03/2021

501000020085

'C' Outboard MSIV Failed to Stroke

11/16/2018

501000020811

Loss of Comp. Assessment in CAS / SAS

2/06/2018

501000020960

Potential Adverse Trend on Sec UPS

2/11/2018

501000024706

Door-43, HPCI to Tank Room, Seal Loose

03/27/2019

501000025875

MO-2076 RCIC Otbd Over App J Admin Limit

04/19/2019

501000026810

RWCU Flow FT-12-4-75A 0 Flow Off Calibration

05/03/2019

501000027548

Shutdown Safety Lessons Learned From ACE

05/17/2019

501000027682

Drywell CAM Reading Trending Upward

05/21/2019

501000027946

ECCS Leakage Program Boundary - HPCI/RCIC

05/30/2019

501000028365

AS-78, AS-79 Found Open

06/11/2019

501000031053

ESW-1-2 IST Test Not Performed in 1R29

08/21/2019

501000032661

Updates to Access Review List (ARL)

10/03/2019

501000036077

SAP Functional Locations, Security Equipments

2/26/2019

501000036402

Receipt Issues with Refurbed MSIV Actuators

01/09/2020

71152B

Corrective Action

Documents

501000037221

20 FP Insp: Fire Flow Test Concerns

01/30/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

501000040114

Operating Permit Use Issue Identified

04/29/2020

501000040145

Suspected RC-50-2 Seat Leakage

04/30/2020

501000040279

Documentation Error in Calc 14-037

05/05/2020

501000040878

Void was Found at Location CSP-B10

05/21/2020

501000042946

ANS Siren Actuation Test Issue

08/06/2020

501000043536

Dr-25 Not Design HELB Water Ht.

08/26/2020

501000044138

TSC Vulnerability

09/15/2020

501000044842

Anonymous CAP: Security LTA PI&R

09/29/2020

501000045576

Downgrade of NLO Must Perform Tasks

10/16/2020

501000045723

Improvement Opportunity for HELB

10/22/2020

501000045769

Apparent Cause Evaluation: CV-1052 demand signal went to

100%

501000048045

Apparent Cause Evaluation: LHRA T.S. Compliance/Dose

Rate Alarms

501000048823

Comanche Peak OE - Grid Frequency

2/18/2021

501000048909

EPRI Part 21 Info Transfer - DLL 3.1

2/23/2021

501000048959

EPRI Part 21 Limitorque Fatigue Life

2/23/2021

501000049788

Lack of Contingency for CAP 501000047989

03/23/2021

501000050558

Apparent Cause Evaluation: Late Identified Scheduled Risk

04/16/2021

501000051042

RWCU/RBCCW Drain Improvement

04/25/2021

501000051048

MO-2397 Exceeded Appendix J Administrative Limit

04/25/2021

501000051150

MO-2397 Failed Leak Rate Test (0137-12)

04/27/2021

501000051151

MO-2398 Failed Leak Rate Test (0137-12)

04/26/2021

501000051496

MO-2397 Exceeded Appendix J Administrative Limit

05/04/2021

501000051763

EDG Relay Failed to Pick Up

05/09/2021

501000051829

MO-2-3/43A Pressure Lock Damage

05/12/2021

501000053565

Inattentive Officer

06/28/2021

501000053835

Apparent Cause Evaluation: Loss of Security Power During

298-02

07/07/2021

501000054313

NOS: Clarity on Termination Timeliness

07/23/2021

501000054841

Unexpected Security Response

08/07/2021

501000056255

GEH Safety Communication 21-07 R0 Issued

09/21/2021

501000056520

TSO Notification Voltage Violation

09/28/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

501000056540

RMAs Not Entered for Yellow Risk

09/29/2021

501000057782

P-160B PMT Didn't Have 3108 Step

10/27/2021

501000058188

SBLC Pump Flow High Out of Band

11/10/2021

501000058336

Mid-Cycle Gap to Excellence PI.1-14

11/16/2021

501000058604

Unauthorized USB Media Used on CDA

11/23/2021

501000059356

Issues found on 4KV Sec Disc EAASHG-1's

03/15/2022

501000059738

DWFDS ROC Increase

01/13/2022

501000059965

Inattentive Security Officer

01/22/2022

501000059988

Apparent Cause Evaluation: XR-7-2 Body to Bonnet Leak

Identified

501000061303

PART 21 Lists Prairie Island impacted

06/17/2022

501000061419

ECR Cancelled Due to Lack of Funding

03/18/2022

501000062426

NRC Obs. Security Defensive Positions

04/20/2022

501000062468

EDG FO Pumps Found Running, 12 EDG Inoperable

04/21/2022

501000062473

CAPR Re-evaluation

04/22/2022

501000062808

Steam Leak on MS-23-2

05/05/2022

501000063050

Door 209 Ingress Reader

05/12/2022

501000063075

MS-24-2 Packing Leak

05/13/2022

501000063092

Steam Leaks Mean High Post-LOCA Dose

05/13/2022

501000064506

Evaluate Comp Measures for Harmonics PM

07/07/2022

501000064672

RWCU Trip

07/12/2022

600000834812

Effectiveness Review of CAP Training

11/29/2021

600000899222

NRC PART 21 2020-33-00

07/16/2021

600000966000

NRC PART 21 2021-27-00

2/01/2022

600001027260

NRC PART 21 2022-05-00

07/15/2022

610000001120

INPO Rapid OE: Weakness in Rad Shipping

2/01/2021

610000001195

OEER: NRC RG 1.200, Rev 3

2/25/2021

610000001343

OEER: NRC RG 1.205 Rev. 2

07/16/2021

610000001394

Operating Experience Evaluation (OEER) NRC RG 1.175 R1

09/01/2021

610000001433

OEER: NRC RG 1.21 Revision 3

09/15/2021

501000066808

22 PIR ACE Closure Quality

09/29/2022

501000066840

PIR No Open WO for MO-2397

09/29/2022

Corrective Action

Documents

Resulting from

501000066842

PIR Inadequate Action Closure

09/30/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

501000066875

PIR - EWI-08.06.02 Figure 1

10/03/2022

501000066884

PIR - Incorrect Priority Placed on CA

10/03/2022

501000066939

Gaps Identified in Scaffold Proc Use

10/05/2022

501000066944

Questions on Torus Scaffold Ladder

10/05/2022

501000066951

Loss of Documentation

10/04/2022

501000067024

PIR Wrong Basis for Mgmt. Exception

10/07/2022

501000067049

PI&R Inaccuracies Identified in SSA

10/10/2022

501000067096

PIR ACMP Closure Action Documentation

10/11/2022

501000067108

PIR Procedures Not Updated Timely

10/11/2022

501000067109

PIR CAPs Closure Quality

10/11/2022

501000067156

PIR Improper Due Date Extension

10/12/2022

Inspection

501000067611

PIR Closure Quality Pot Trend

10/20/2022

Adverse Condition Monitoring Plan - Drywell CAM Reading

Trending Upward

05/31/2019

A-OPS-MNGP-

21-1

21 Nuclear Oversight Audit of Monticello Nuclear

Generating Plant Operations/Chemistry

2/26/2021

Nuclear Oversight

Audit Report A-

FLEX-MNGP-

2018-1

MNGP NOS FLEX Special Audit 2018

2/08/2018

Nuclear Oversight

Audit Report A-

MAINT-MNGP-

22-1

Maintenance

05/02/2022

Miscellaneous

Utilities Service

Alliance Nuclear

Safety Culture

Assessment

Xcel Energy Nuclear Safety Culture Assessment 2022

06/23/2022

275-03

Fire Door Inspections

297-02

PAL UPS / Security UPS Battery

Operability Check - Quarterly

297-02

PAL UPS / Security UPS Battery

Operability Check - Quarterly

Procedures

298-02

Security System Emergency Generator

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Operability Check & Alarm

B.09.03-05 - H.5

System Contingency Voltage Notification

EWI-08.06.01

MNGP Primary Containment Leakage Rate Testing Program

EWI-08.06.02

LLRT Extended Eligibility Determination

FG-G-PCR-01

Procedure Change Request (PCR) Initiation, Screening, and

Processing

FG-PA-EVAL-01

Evaluation Methods

FP-MA-FSC-01

Scaffolding

FP-MA-VPI-01

Valve Packing Installation and Adjustment

FP-OP-OL-01

Operability

FP-PA-ARP-01

CAP Process

FP-PA-ARP-03

Management of Change (MOC) Process

FP-PA-OE-01

Operating Experience Program

FP-PA-SOER-01

Significant Operating Experience Report (SOER) Processing

FP-S-AA-01

Access Authorization Program

FP-S-FSIP-07

Access Controls

FP-STND-SCP-

Station Common Priority Scheme

2000016617

Review of Open CAP Activities with Management Exception

LTA Flag

03/31/2022

2000016617

21 CAP CA Quality Closure Snapshot

2/31/2021

606000001164

20 CAP CA Closure Snapshot

2/31/2020

606000001196

Implementation of Flexible Power Operations (FPO)

Following Receipt of a MISO Award

2/10/2021-

2/14/2021

606000001365

Access Authorization Snapshot

10/29/2021

606000001381

Security Review of Part 37 Program Snapshot

2/01/2021

606000001406

21 NRC EP Exercise and Inspection

06/2021-

07/2021

606000001553

FSA: Problem Identification & Resolution at MNGP

03/25/2022

A-CYBER-FLT-

21-1

21 Nuclear Oversight Audit of Fleet Cyber Security and

Security

08/19/2021

Self-Assessments

A-SEC-FLT-2020-

20 Nuclear Oversight Audit of Fleet Security and Cyber

Security

08/20/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

700052249

QIM_501000024706_Door-43, HPCI to Tank Room, Seal

Loose

03/29/2019

700055395

Reactor Steam Supply Valves Leak Rate Testing

05/10/2021

700066828

Perform 8905 Prior To CSP Venting DIV 2

2/23/2021

700082979

UPS-PAL-1 2YR PM

09/15/2021

Work Orders

700083080

UPS-PAL-2 2YR PM

04/16/2021