ML22024A215
| ML22024A215 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 01/25/2022 |
| From: | Eric Michel NRC/RGN-II/DFFI/FFB2 |
| To: | Stephens L Framatome |
| Goff G | |
| References | |
| IR 2021004 | |
| Download: ML22024A215 (17) | |
Text
January 25, 2022 Mr. Lance Stephens, Site Manager Framatome Inc.
2101 Horn Rapids Road Richland, WA 99354
SUBJECT:
FRAMATOME-RICHLAND - INTEGRATED INSPECTION REPORT 07001257/2021004
Dear Mr. Stephens:
On November 18, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Framatome-Richland and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
No violations of more than minor significance were identified during this inspection.
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, Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 07001257 License No. SNM-1227
Enclosure:
As stated cc w/ encl: Distribution via LISTSERV Signed by Michel, Eric on 01/25/22
SUNSI Review x
Non-Sensitive
Sensitive x
Publicly Available
Non-Publicly Available OFFICE RII/DFFI/PB2 RII/DFFI/PB2 RII/DFFI/PB2 RII/DFFI/PB2 RII/ORA NAME G. Goff C. Taylor E. Michel T. Sippel K. McCurry DATE 01/18/2022 01/18/2022 01/18/2022 01/18/2022 01/18/2022
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
07001257 License Number:
SNM-1227 Report Number:
07001257/2021004 Enterprise Identifier:
I-2021-004-0128 Licensee:
Framatome Inc.
Facility:
Framatome-Richland Location:
Richland, WA Inspection Dates:
November 15 - 19, 2021 Inspectors:
G. Goff, Fuel Facilities Inspector K. McCurry, Technical Assistant T. Sippel, Fuel Facilities Inspector Approved By:
Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Framatome-Richland, in accordance with the fuel cycle facility inspection program. This is the NRCs program for overseeing the safe operation of licensed fuel cycle facilities. Refer to https://www.nrc.gov/materials/fuel-cycle-fac.html for more information.
List of Violations No violations of more than minor significance were identified.
Additional Tracking Items Type Issue Number Title Report Section Status WER 07001257/2021-002-00 Sea-Land Container Contamination Event (EN 55517) 88055 Closed
3 PLANT STATUS The Framatome facility converts uranium hexafluoride (UF6) into uranium dioxide (UO2) for the fabrication of low-enriched fuel assemblies used in commercial light water reactors. During the inspection period, normal production activities were ongoing.
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. Inspections were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2600, Fuel Cycle Facility Operational Safety and Safeguards Inspection Program. 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.
SAFETY OPERATIONS 88015 - Nuclear Criticality Safety The inspectors evaluated selected aspects of the licensees Nuclear Criticality Safety (NCS) program to verify compliance with selected portions of 10 Code of Federal Regulation (CFR) 70, including 70.50, 70.61, 70.62, and Appendix A; Chapter 5, Nuclear Criticality Safety, of the facilitys license application; and applicable licensee procedures.
Criticality Analysis (IP Section 02.01)
The inspectors interviewed licensee staff and reviewed nuclear criticality safety analyses (NCSAs), associated assumptions, and calculations to verify compliance with 10 CFR 70 and applicable sections of the license application, including the integrated safety analysis (ISA) program defined in Chapter 3, nuclear criticality safety program administration requirements committed to in Chapter 5, and configuration and maintenance of management measures laid out in Chapter 11. Specifically, the inspectors interviewed licensee NSC staff and reviewed the following NCSAs:
4
E04-NCSA-190, UO2 Pellet Dissolution, Version 17.0, including the review of all credible accident sequences, application of the double contingency principle, demonstration that the likelihood of each scenario remained highly unlikely with credited items relied on for safety (IROFS), and the basis for why the licensee screened accident sequences 4.1, 6.1, 6.2, 7.5, and 7.6 as not credible
E04-NCSA-370, UO2 Pellet Pressing, Version 16.0, including the review of recent revisions; accident sequences 3.2, 3.5, and 4.3; associated IROFS 1623, 1624, and 2803; and the basis for normal, credible abnormal, and non-credible accident scenarios
E04-NCSA-790, Development, Process Support & Analytical Lab, Version 23.0, including the review of recent revisions and the basis for normal, credible abnormal, and non-credible accident sequences Criticality Implementation (IP Section 02.02)
The inspectors selected passive and active engineered and administrative and enhanced administrative controls from the licensees ISA summary to verify proper implementation through a review of process and system descriptions, plant walkdowns, and operator interviews to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors interviewed the system operator and supervisor and reviewed the following controls and the management measures associated with the UO2 Pellet Dissolution NCSA listed above:
IROFS 0.20, geometry control, passive engineered, verified through system walk-down
IROFS 1632, moderation control, passive engineered, verified through system walk-down
IROFS 2107, spacing control, administrative, verified through operator interview and system walk-down
IROFS 2803, moderation control, passive engineered, verified through system walk-down
IROFS 3209, mass control, enhanced administrative, verified through procedure review, operator interview, and annual functional test record
IROFS 3217, geometry/mass control, passive engineered, verified through system walk-down and annual functional test record
IROFS 3220, 3224, and 3226, geometry/mass controls, passive engineered, verified through system walk-down and annual functional test record
IROFS 3225 and 3225.10, geometry/mass controls, active engineered, verified through procedure review, operator interview, and annual functional test record
IROFS 6108, moderation/geometry control, administrative, verified through procedure review and operator interview Criticality Operational Oversight (IP Section 02.03)
The inspectors assessed the NCS staffs oversight of plant operators, procedures, and operations of systems involving special nuclear material to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors performed the following activities:
5
conducted a system walk-down of the UO2 Pellet Dissolution process (System 190) with NCS staff
interviewed the System 190 operator concerning criticality hazards and control methods, including the use of IROFS listed above, and reviewed his completed NCS training records
interviewed the System 190 supervisor for the same issues
reviewed the System 190 standard operating procedure, SOP-40284, Pellet Dissolver for ADU Process, Version 13.0
reviewed a System 370 standard operating procedure, SOP-40503, Physical Inventory of Nuclear Material, Version 23.0
reviewed monthly NCS audit/inspection reports that cover a sample of process systems, operator observations, and NCS infraction trends
identified no plant modifications to System 190 were conducted in the 12 months prior to the inspection
identified no maintenance activities were performed while the inspectors were on-site Criticality Programmatic Oversight (IP Section 02.04)
The inspectors reviewed NCS program procedures, audits, and NCS staff qualifications to verify compliance with 10 CFR 70 and applicable sections of the license application.
Specifically, the inspectors interviewed licensee NCS staff and reviewed the following documents:
recently revised NCS procedure E04-05-01, Nuclear Criticality Safety Standards, Version 18.0
recently revised NCS procedure E04-06-004, Preparation & Review of Nuclear Criticality Safety Documents, Version 13.0
NCS qualification records for a new Criticality Safety Analyst
the most recent external audit of the licensee's NCS program documented in a Triennial Assessment dated July 23, 2021
the NCS validation report to confirm it has not been revised since July of 2019 Criticality Incident Response and Corrective Action (IP Section 02.05)
The inspectors reviewed the licensees corrective action program (CAP) to verify compliance with 10 CFR Part 70 and applicable sections of the license application. Specifically, the inspectors reviewed licensee identified issues related to NCS and the associated corrective actions, extent of conditions, causal analyses, and Appendix A reportability evaluations, as well as interviewed licensee staff regarding the following condition reports (CRs):
6
CR-2021-0497
CR-2021-1077
CR-2021-1391
CR-2021-1681
CR-2021-1755
CR-2021-1790
CR-2021-1842
CR-2021-2147
CR-2021-2237
CR-2021-2532 88055 - Fire Protection The inspectors evaluated selected aspects of the licensees fire protection program to determine whether the operational status, material condition and design of fire protection systems met the applicable requirements of 10 CFR 70; Chapter 7, Fire Safety, of the facilitys license application; and applicable licensee procedures.
Selection of Inspection Samples (IP Section 02.01)
The inspectors reviewed licensing documents to select a sample of fire protection features in risk-significant areas/processes, including IROFS and their respective management measures. The inspectors also selected licensee activities that support the implementation of the fire protection program based on the program description included in the license application. Specifically, the inspectors reviewed the following:
IROFS 4502 and IROFS 4503; as applied to System 380 - UO2 Pellet Sintering, System 545 - Product Development Test Facility, and the Solid Waste Uranium Recovery (SWUR) section in the Specialty Fuels Building
E14-01-005, UO2 Ceramics, Version 5.0, which included the process hazards evaluation for UO2 Pellet Sintering
E14-02-004, UO2 Building Fire Hazards Analysis, Version 9.0, which included the fire hazard analysis for UO2 Pellet Sintering
E14-03-001, Radiological and Toxicological Consequences from Uranium, Version 14.0 Preventative Controls (IP Section 02.02)
The inspectors interviewed licensee staff, reviewed documentation, and conducted plant walk-downs to verify the licensees controls for combustibles and ignition sources met the license requirements and applicable requirements in 10 CFR 70. Specifically, the inspectors conducted the following inspection activities:
7
interviewed licensee engineers and technicians
reviewed records of monthly licensee walk-downs (IROFS 4503)
performed plant walk-downs in the areas of the UO2 Sintering Furnaces, the Product Development Test Facility, UO2 Pellet Dissolution, and SWUR (IROFS 4502)
Fire and Gas Detection and Alarm Systems (IP Section 02.03)
The inspectors reviewed selected fire detection devices to verify that detection and alarm systems were able to initiate the safety function credited in fire hazard analysis (FHA) and/or the ISA Summary. Specifically, the inspectors conducted the following inspection activities:
interviewed licensee technicians responsible for testing gas detectors
reviewed a sample of records for detector tests and calibration
conducted walk-downs of gas detectors near the UO2 Sintering Furnaces
reviewed a sample of records for heat detector tests
conducted walk-downs of heat detectors
interviewed licensee engineers concerning fire protection controls and responses to fire events
conducted walk-downs of the main fire alarm panel to verify its functionality for displaying the location of an alarm or other fire-related trouble alerts such as tampering with the fixed position of certain flow control valves Suppression Systems and Activities (IP Section 02.04)
The inspectors interviewed licensee staff, reviewed fire protection program documents, and conducted plant walk-downs to verify that suppression systems could perform the safety function credited in the license application. Specifically, the inspectors performed the following activities:
conducted walk-downs of the sprinkler system in the SWUR (IROFS 4535.10) including the flow and valve position alarms on the riser and the location and material condition of the sprinkler heads
conducted walk-downs of the fire extinguishers in selected plant areas, including the Product Development Test Facility workshop (which is a hot work area)
reviewed numerous maintenance records for the testing/functionality of the sprinkler systems Passive Fire Protection Features (IP Section 02.05)
The inspectors reviewed selected passive fire protection features to verify these were in a proper material condition to perform the safety function credited in the license application, and the ISA Summary. Specifically, the inspectors performed the following activities:
8
conducted a walk-down of a firewall in SWUR (IROFS 4536)
reviewed MCP-30031, Flammable and Combustible Liquids/Solids Storage &
Handling, Version 13.0
conducted walk-downs of various fire doors and fire dampers Fire Protection Program Elements (IP Section 02.06)
The inspectors reviewed selected fire protection program elements to verify compliance with the license requirements. Specifically, the inspectors performed the following activities:
reviewed justification for continued operations (JCOs) for 2021
reviewed training records for the Plant Emergency Response Team (PERT) relative to the required fire training aspects
reviewed the training requirements and records for fire response for a sample of selected employees
interviewed operators regarding their response to a fire in various stages
interviewed firefighting personnel and security personnel regarding automatic off-site notification to the Richland Fire Department in the event of a fire alarm
conducted walk-downs of emergency lighting systems in buildings that contain or process special nuclear material (SNM)
Identification and Resolution of Problems (IP Section 02.07)
The inspectors reviewed the licensees identification and resolution of fire protection issues to verify compliance with the license requirements. Specifically, the inspectors reviewed the following corrective action program entries, audits, and self-assessments:
9
CR-2020-0011
CR-2020-1612
CR-2021-1354
CR-2021-1508
CR-2021-1538
CR-2021-1979
CR-2021-2410
CR-2021-2410-01
CR-2021-2410-02
CR-2021-2410-03
AXA XL Risk Consulting Report - Property Risk Control - Loss Prevention Report, 04/21-22/2021
13502742, CG06P014 Fire Wall Inspection 6Mo SA, 04/30/2021
13515245, CG06P003 Safety Inspection 1 Mo OPCR, 07/27/2021
13522566, PM005091 Smoke/Duct Smoke Visual 6 Mo EL, 09/21/2021
13522573, CG06P001 Safety Inspection 1 Mo OPCH, 09/25/2021
13522574, CG06P002 Safety Inspection 1 Mo OPWA, 09/24/2021
CG06P012, Fire Hydrant Flow Test 12 MO RE, 05/06/2021
CG06P017, Fire Door (#63) SF 174 12 MO RE, 07/22/2021
CG06P019, Fire Sprinklers 3MO PS (3rd Quarter), 08/12-16/2021
Event Notification 55517 - 70.50(b)(1) - Sea-Land Container Contamination INSPECTION RESULTS WER Closed Sea-Land Container Contamination Event (EN 55517)
WER 07001257/2021-002-00 88055
==
Description:==
This was a 24-hour report for an unplanned contamination event that required access to the contaminated area, by workers or the public, to be restricted for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by imposing additional radiological controls or by prohibiting entry into the area.
A process operator, using a forklift, was attempting to move a pallet of four plastic 55-gallon drums containing uranyl nitrate (UN) solution. Two drums fell off the pallet and into the sea-land container where they were stored. One of the drums split and leaked UN solution into the sea-land container contaminating an area within the sea-land container, the forklift, and the asphalt underneath and adjacent to it. As part of a routine inspection conducted the week of November 15th, 2021, the inspectors walked down the area of the incident and inspected the licensee's response actions. A review of the worst-case scenario dose calculations and the licensees 30-day report (ADAMS ML21336A759) was subsequently conducted. No violations of NRC requirements were identified. This EN is considered closed.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On November 18, 2021, the inspectors presented the integrated inspection results to Timothy Tate, Manager of Safety, Security, and Emergency Preparedness, and other members of the licensee staf
10 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision (Rev.),
- Version, or Date 88015 Corrective Action Documents CR-2021-0497 CR-2021-1077 CR-2021-1391 CR-2021-1681 CR-2021-1755 CR-2021-1790 CR-2021-1842 CR-2021-2147 CR-2021-2237 CR-2021-2532 88015 Corrective Action Documents Resulting from Inspection CR-2021-2862 NRC Inspection 2021-004 11/18/2021 88015 Engineering Evaluations E04-NCSA-190 UO2 Pellet Dissolution Version 17.0 88015 Engineering Evaluations E04-NCSA-370 UO2 Pellet Pressing Version 16.0 88015 Engineering Evaluations E04-NCSA-790 Development, Process Support & Analytical Lab Version 23.0 88015 Miscellaneous HRR-CRT-200000 Assessment Criticality Safety Analyst Academic Knowledge Confirmation, Plateau User ID 56491 07/07/2021 88015 Miscellaneous User No. T6674 HRR-SAF-CRITICALITY SAFETY 06/23/2021 88015 Procedures E04-05-01 Nuclear Criticality Safety Standards Version 18.0 88015 Procedures E04-06-004 Preparation & Review of Nuclear Criticality Safety Documents Version 13.0 88015 Procedures E12-03-045 Item Control Version 9.0 88015 Procedures SOP-40284 Pellet Dissolver for ADU Process Version 13.0 88015 Procedures SOP-40503 Physical Inventory of Nuclear Material Version 23.0 88015 Self-Assessments E04-07-202108 NCS Audit/Inspection Report - August 2021 Version 1.0
11 88015 Self-Assessments E04-07-202109 NCS Audit/Inspection Report - September 2021 Version 1.0 88015 Self-Assessments E04-07-202110 NCS Audit/Inspection Report - October 2021 Version 1.0 88015 Self-Assessments E12-03-045-FRM-001 Item Control Audit Form Version 2.0 88015 Self-Assessments FRA_D3SEP_IG_21-022_IR Inspection Report, Nuclear Criticality Safety (NCS), Richland Horn Rapids Road (HRR)
[Triennial NCS Assessment]
07/23/2021 88015 Work Orders Order 13494286 C190P003 Pelt Disolvr Intlks 12MO OPCH 03/17/2021 88015 Work Orders Order 13497975 C820P015-0001 Wall Thick/Filters 5Y MW 08/05/2021 88015 Work Orders Order 13497976 C820P017-0001 WL Thck/Calc Rcvrs 5Y MW 08/05/2021 88015 Work Orders Order 13498021 C100P001 L2 Overflow /
Vents 12MO PF 03/10/2021 88055 Corrective Action Documents CR-2020-0011 01/02/2020 88055 Corrective Action Documents CR-2020-1612 08/07/2020 88055 Corrective Action Documents CR-2021-1354 06/02/2021 88055 Corrective Action Documents CR-2021-1508 06/24/2021 88055 Corrective Action Documents CR-2021-1538 06/29/2021 88055 Corrective Action Documents CR-2021-1979 08/30/2021 88055 Corrective Action Documents CR-2021-2410 10/12/2021 88055 Corrective Action Documents CR-2021-2410-01 11/01/2021 88055 Corrective Action Documents CR-2021-2410-02 11/01/2021
12 88055 Corrective Action Documents CR-2021-2410-03 11/01/2021 88055 Corrective Action Documents Resulting from Inspection CR-2021-2833 11/17/2021 88055 Drawings CSA-611932 Hydrogen P&ID Rev. 5 88055 Drawings EMF-608610 Horn Rapids Road Site Arrangement Fire &
Water Supply Rev. 25 88055 Drawings EMF-611380 Line 1 Sintering Furnace, Sheets 1 and 2 Rev. 2 88055 Drawings EMF-611930 H2/N2 Supply P&ID Rev. 15 88055 Drawings EMF-616750 Fire Alarm System ESI3 Network/Panel Configuration Flow Diagram Rev. 1 88055 Engineering Evaluations 1703-76-F01 Apparent Cause Analysis for CR 2021-2410 10/28/2021 88055 Engineering Evaluations E04-NCSA-761 Between Building Transfer Version 25 88055 Engineering Evaluations E13-03-001 Radiological and Toxicological Consequences from Uranium Version 14.0 88055 Engineering Evaluations E14-01-005 UO2 Ceramics Version 5.0 88055 Engineering Evaluations E14-02-004 UO2 Building Fire Hazards Analysis Version 9.0 88055 Engineering Evaluations E24-01-001 Fire Hazard Analysis -
Horn Rapids Road Site Version 7.0 88055 Engineering Evaluations E24-01-199 Fire Hazards Analysis -
Misc Facilities with SNM and Radiological Hazards Version 6.0 88055 Miscellaneous Evaluation of Reportability for: UN Barrel Spill at MERF 10/12/2021 88055 Miscellaneous Spreadsheet Calculation for Dose from a Worst Case Scenario for the UN Barrell/Contamination Spill at MERF 11/17/2021 88055 Miscellaneous CG06P012 Fire Hydrant Flow Test 12 MO RE 05/06/2021 88055 Miscellaneous CG06P017 Door Fire (#63) SF 174 12MO RE 07/22/2021
13 88055 Miscellaneous CG06P019 Fire Sprinklers 3MO PS (3rd Quarter) 08/12/2021 88055 Miscellaneous E04-NCSS-G06 Fire Prevention and Firefighting Version 31.0 88055 Miscellaneous E08-04-2.12 Memorandum of Understanding between Framatome Inc. and Richland Fire Department Version 5.0 88055 Miscellaneous E12-01-007 Justification of Continued Operation Under Compensatory Safety Measures - JCO # 2021-006 06/29/2021 88055 Miscellaneous E15-01-2.19 Part 2 - Chapter 19 -
Product Development Test Facility Version 11.0 88055 Miscellaneous E15-01-2.9C Part 2 - Chapter 9C - UO2 Building Version 19.0 88055 Miscellaneous HRR-IND-500001-010-02 Richland Site Access Refresher Training -
Emergency Response /
Worker Health & Safety Training (MCP-30048)
(Slides) 88055 Miscellaneous O-20211013-5 (VSDS One Liner Survey Report)
Contamination Event Record - MERF UN Solution Spill 10/12/2021 88055 Miscellaneous Organizational Chart Fuel Operations Plant Engineering, Technical Support & Maintenance 88055 Miscellaneous Organizational Chart EHS&L Organization 88055 Miscellaneous Temporary Operator Aid Transporting Drums Using Forklifts 10/28/2021 88055 Miscellaneous Training Training Records - 2021 Hands on Fire Extinguisher Training for PERT Personnel (HRR-EP-200005) 05/01/2021 88055 Miscellaneous Training Lesson Plan - 2021 Hands on Fire Extinguisher Training for PERT Personnel (HRR-EP-200005) 05/01/2021 88055 Procedures CG06P001 Fire Hazard Inspection 1Mo OPCH Rev. 9 88055 Procedures CG06P002 Safety Inspection 1Mo OPWA Rev. 13 88055 Procedures CG06P014 Fire Wall Inspection 6Mo SA Rev. 3.0
14 88055 Procedures IRM08428 MSA Model Ultima XE Series Gas Monitor Version 3.0 88055 Procedures MCP-30029 Housekeeping Version 5.0 88055 Procedures MCP-30031 Flammable and Combustible Liquids/Solids Storage &
Handling Version 13.0 88055 Procedures MCP-30039 Hot Work Procedure Version 12.0 88055 Procedures MCP-30532 Essential Materials Class III: HEPA Filters Version 4.0 88055 Procedures PG000195 RPBA 8" Premise Backflow Preventer 12 MO PS August 2021 88055 Procedures PM002323 Hazardous Gas 12 Mo PS Rev. 30 88055 Procedures PM004445 Dry/Wet Chem and UO2 Fire System 6MO PS 02/04/2021 88055 Procedures PM00515 Suppression Fire System (EDM) 6 MO PS 03/05/2021 88055 Procedures SOP-40857 Maintenance Hot Work Permit Procedure Version 12.0 88055 Procedures SOP-41044 Designate Hot Work Area Requirements Procedure Version 7.0 88055 Radiation Surveys Contamination levels of soil samples from the contamination spill 11/04/2021 88055 Radiation Surveys FRM-31191 Fugitive Emissions Contamination Control Plan (FECCP) Form Version 2.0 88055 Radiation Work Permits (RWPs)
O-20211012-1 MERF Radioactive Material Storage Area UNH Spill 10/12/2021 88055 Radiation Work Permits (RWPs)
O-20211018-3 MERF Spill Clean-Up Plan 10/18/2021 88055 Radiation Work Permits (RWPs)
O-20211019-1 MERF Decontamination of Land/Sea Containers 10/19/2021 88055 Radiation Work Permits (RWPs)
O-20211025-5 MERF Forklift Decon 10/25/2021 88055 Self-Assessments AXA XL Risk Consulting Report Property Risk Control -
Loss Prevention Report 04/21-22/2021 88055 Work Orders 13502742 CG06P014 Fire Wall Inspection 6Mo SA 04/30/2021 88055 Work Orders 13515245 CG06P003 Safety Inspection 1Mo OPCR 07/27/2021
15 88055 Work Orders 13522566 PM005091 Smoke/Duct Smoke Visual 6Mo EL 09/21/2021 88055 Work Orders 13522573 CG06P001 Safety Inspection 1Mo OPCH 09/25/21 88055 Work Orders 13522574 CG06P002 Safety Inspection 1Mo OPWA 09/24/2021