ML21302A040

Urenco USA, Integrated Inspection Report 07003103/2021003

ML21302A040
Person / Time
Site:	07003103
Issue date:	10/29/2021
From:	Chutima Taylor NRC/RGN-II/DFFI
To:	Padgett W Louisiana Energy Services, URENCO USA
References
IR 2021003
Download: ML21302A040 (26)

Text

October 29, 2021 Mr. Wyatt Padgett Compliance and Licensing Manager LOUISIANA ENERGY SERVICES (LES) dba URENCO USA URENCO USA P.O. Box 1789 Eunice, NM 88231

SUBJECT:

URENCO USA - INTEGRATED INSPECTION REPORT 07003103/2021003

Dear Mr. Padgett:

On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at URENCO USA (UUSA) 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.

Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC requirements was identified during the inspection. Because UUSA has an NRC-approved corrective action program, placed the violation into their corrective action program, and restored compliance, this violation is being treated as a non-cited violation (NCV) consistent with Section 2.3.2a of the Enforcement Policy. The NCV is described in the subject inspection report. If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at URENCO USA.

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

W. Padgett 2 Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Cynthia D. Taylor, Chief (Acting)

Projects Branch 1 Division of Fuel Facility Inspection Docket No. 07003103 License No. SNM-2010

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

ML21302A040 X Non-Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI NAME B. Adkins L. Cooke C. Taylor DATE 10/26/21 10/26/21 10/29/2021 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07003103 License Number: SNM-2010 Report Number: 07003103/2021003 Enterprise Identifier: I-2021-003-0118 Licensee: LOUISIANA ENERGY SERVICES (LES) dba URENCO USA Facility: URENCO USA Location: Eunice, NM Inspection Dates: August 09 - 12 and September 13 - 16, 2021 Inspectors: B. Adkins, Sr. Fuel Facility Project Inspector L. Cooke, Fuel Facility Inspector T. Sippel, Fuel Facility Inspector P. Startz, Fuel Facility Inspector Approved By: Cynthia D. Taylor, Chief (Acting)

Projects Branch 1 Division of Fuel Facility Inspection Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at URENCO USA (UUSA), 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 Criticality Accident Alarm System (CAAS) inaudibility not reported Significance Report Section Severity Level (SL) IV 88015 Non-Cited Violation (NCV) 07003103/2021003-01 Open/Closed The NRC inspectors identified a SL-IV NCV of the reporting requirements in 10 Code of Federal Regulation (CFR) 70.50(b)(2).

Additional Tracking Items None.

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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 70.24, 70.50, 70.61, 70.62, and Chapter 5, Nuclear Criticality Safety, of the facilitys safety analysis report (SAR), and applicable licensee procedures.

Criticality Analysis (IP Section 02.01)

The inspectors interviewed licensee staff and reviewed nuclear criticality safety analyses (CSAs), and associated documentation, to verify compliance with 10 CFR 70 and applicable sections of the SAR, including, 5.1.2, 5.2.1.3, and 5.2.1.4. Specifically, the inspectors interviewed licensee staff and reviewed the following:

• NCS-CSA-006, "Criticality Safety Analysis of the Product Vent Pump and Chemical Trap Set," Revision (Rev.) 10, because it contained a variety of calculations and information supporting the licensee's evaluation of Safe-By-Design (SBD) components in the Product Liquid Sampling and Product Takeoff Systems Criticality Implementation (IP Section 02.02)

The inspectors selected SBD controls from the licensees integrated safety analysis summary (ISAS) to verify proper implementation through a review of process and system descriptions, records, and plant walkdowns to verify compliance with 10 CFR 70 and applicable sections of the SAR, including 3.2.5.2. Specifically, the inspectors performed the following activities:

• reviewed SBD verification (SBDV) forms and nuclear safety releases (NSRs) performed by the licensee for the product liquid sampling and product takeoff systems;

• walked down NCS postings and storage areas for fissile baring waste in the cylinder receipt and dispatch building (CRDB); and

• walked down favorable geometry accumulation points (e.g., traps) in the product liquid sampling and product takeoff systems.

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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 SAR. Specifically, the inspectors performed the following activities:

• reviewed the criticality general employee training (GET)/computer-based training (CBT) material for compliance with Chapter 11 of the SAR;

• walked down the product liquid sampling and product takeoff systems with a qualified NCS engineer; and

• observed a licensee NCS support staff member conduct a weekly walkthrough audit of the separations building module (SBM)-1003 criticality accident alarm system (CAAS).

Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed NCS program procedures, and NCS staff qualifications to verify compliance with 10 CFR 70 and applicable sections of the SAR, including 2.2.3.F, 5.1.1, and 5.1.5. Specifically, the inspectors interviewed licensee NCS staff and reviewed the following documents:

• procedure used for non-destructive verification of materials used in SBD components (QA-3-3000-36);

• qualification guides for licensee NCS engineers and NCS support staff (E-NCS-QG, and E-NCS-SS);

• training records for NCS staff; and

• annual continuing training records for a senior NCS engineer.

Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensees CAAS, criticality emergency response procedures, and corrective action program (CAP) to verify compliance with 10 CFR 70. Specifically, the inspectors performed the following activities:

• reviewed a sampling of CAAS and NCS-related CAP entries since the last NCS inspection;

• reviewed records of recent maintenance and testing of the CAAS, specifically work orders (WOs) 1000489860 and WO 1000500490;

• interviewed licensee NCS and radiological protection (RP) staff concerning recent NCS drills, and their roles in emergency response;

• walked down RP equipment that would be used during and after potential criticality accidents; and

• reviewed a sample of emergency action plans, including the instructions and evacuation maps to follow during a CAAS activation.

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88020 - Operational Safety The inspectors evaluated selected aspects of the licensees Operational Safety program to verify compliance with selected portions of 10 CFR 70, including 70.61, 70.62, and Chapter 11, Management Measures, of the facilitys SAR, and applicable licensee procedures.

Identification of Safety Controls and Related Programs (IP Section 02.01)

The inspectors selected specific process areas for inspection based on the safety basis information of the facility, the risk and safety significance of the process areas, the description of plant changes submitted to the NRC, and past plant performance documentation. For the process areas of interest, the inspectors selected a sample of accident sequences in fire safety and chemical safety based on the information provided in the ISAS. The inspectors conducted a general plant tour of each major plant operating area. The process areas and accident sequences selected for review are listed below:

• FF-WORKER-EVAC, fire involving excessive transient combustibles within the area or a fire propagating into the area of concern that could result in a fire of sufficient magnitude that results in a release of uranium hexafluoride (UF6);

• FF6-1, fire propagating into the CRDB general areas from other areas that could result in a release of UF6 inventory;

• FF15-1, fire propagating into the UF6 handling area from other areas that could result in a release of uranium material;

• PB4-2, product liquid sampling autoclave heater fails causing heater to remain on resulting in cylinder and autoclave failure and release of UF6 inventory; and

• PT2-1, product low temperature takeoff station heater defrost controller heater fails causing cylinder and autoclave failure and release of UF6 inventory.

Review of Safety Controls and Related Programs (IP Section 02.02)

The inspectors reviewed information related to administrative and engineered safety controls or items relied on for safety (IROFS) for the accident sequences selected above, including the identification of the licensees assumptions and bounding cases as they apply to each of the selected accident sequences, safety controls, or IROFS. This review was performed to verify that the controls or IROFS were available and reliable to perform their intended safety functions and that the design basis assumptions were reflected in the actual conditions in the field. The specific safety controls selected for review are listed below:

• IROFS1, automatic trip of a defrost heater and fan on high internal temperature to ensure cylinder integrity (RTD), active engineered control; chemical safety;

• IROFS2, automatic trip of a defrost heater and fan on high internal temperature to ensure cylinder integrity (thermocouple); active engineered control, chemical safety; IROFS11, automatic trip of the autoclave heater and fan on high internal temperature to ensure product liquid sampling autoclave integrity; active engineered control, chemical safety;

• IROFS12, automatic trip of the autoclave heater and fan on high autoclave internal pressure to ensure product liquid sampling autoclave integrity; active engineered control, chemical safety; 5

• IROFS 35, automatic closure of fire-rated barrier opening protectives (fire dampers), administrative control, fire and chemical safety; and

• IROFS39b, administratively limit exposure by requiring operator action to evacuate the area of concern to ensure worker consequences of inhalation of uranic material and hydrogen fluoride (HF) are low; administrative control, fire and chemical safety.

Implementation of Safety Controls (IP Section 02.03)

For the selected safety controls listed above, the inspectors reviewed management measures to verify proper implementation in accordance with 10 CFR 70 and applicable sections of the SAR. This review was performed to verify that selected safety controls or IROFS were present, available, and reliable to perform their safety function and that the design basis assumptions were reflected in the actual conditions in the field. The inspectors conducted the following activities to verify the implementation of selected safety controls:

• reviewed maintenance procedure MA-3-3400-11 and observed the annual IROFS1/2 surveillance test for station 1003-434-7B3;

• reviewed IROFS11/12 engineering setpoint calculations associated with accident sequence PB4-2;

• reviewed records to determine if IROFS35 fire dampers were properly tested in accordance with National Fire Protection Association (NFPA) 90A requirements; and

• conducted interviews and reviewed training records to determine if personnel were knowledgeable of evacuation and incipient firefighting procedures as specified in the boundary definition for IROFS39b.

Safety Control Support Programs (IP Section 02.04)

The inspectors assessed additional management measures that support the availability and reliability of the selected safety controls to verify these were implemented in accordance with 10 CFR 70 and applicable sections of the SAR. Specifically, the inspectors performed the following:

• reviewed WO 1000366586 for IROFS35 and WOs 1000420321/1000438976 for IROFS 11 and 12 to determine if the licensee was adequately performing IROFS-related functional testing at the proper frequency;

• reviewed the following CAP entries to ensure the licensee was entering items at the proper threshold and correcting conditions adverse to quality and safety: event (EV) 123337, 137862, 146038, 145904, 145835, 144688, 144687, 143321, 143082, 140675;

• attended the plan of the day meeting on 08/10/2021 to determine if the licensee was adequately controlling work and addressing operational deficiencies;

• reviewed the operations department organizational chart for compliance with Chapter 2 of the SAR; 6

• performed interviews of five plant operators to determine their knowledge related to IROFS39b including the required actions they would take in the event of a fire; and

• observed operations shift turnover on 08/10/2021.

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 SAR, 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 and processes, including ROFS and their respective management measures (where applicable). The inspectors also selected licensee activities that support the implementation of the fire protection program based on the program description included in the SAR. Specifically, the inspectors performed the following:

• observed a weekly IROFS36A combustible material loading walkdown by operations personnel;

• observed maintenance and post maintenance testing on IROFS35 fire doors under WOs 1000496137 and 1000496138;

• observed hot work practical training including use of fire extinguishers;

• interviewed one control room operator and one control room supervisor regarding operation of the fire water system; and

• reviewed electronic operating logs to determine if the licensee was maintaining minimum fire water tank levels.

Preventative Controls (IP Section 02.02)

The inspectors interviewed licensee staff, reviewed documentation, and conducted plant walk-downs to verify the licensees controls for transient combustibles and ignition sources met the license requirements and applicable requirements in 10 CFR 70. Specifically, the inspectors conducted the inspection activities listed below:

• interviewed licensee operators and engineers, reviewed records of walkdowns, and conducted plant walk-downs in the CRDB, SBM-1001 and other areas to verify controls for transient and fixed combustible material were being implemented in accordance with procedural requirements;

• conducted plant walk-downs, interviewed engineers and maintenance personnel, and reviewed records to verify ignition sources were controlled in accordance with procedural requirements; and

• reviewed records of hot work conducted to verify that compensatory measures were taken and that hot work permits were renewed daily.

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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 detect the minimal fire within the required time and initiate the safety function credited in the SAR. Specifically, the inspectors conducted the inspection activities listed below:

• interviewed licensee engineers and reviewed records related to the VESDA system; and

• conducted plant walk-downs in SBM-1001 to verify fire detection and alarm systems were installed and maintained as required.

Suppression Systems and Activities (IP Section 02.04)

The inspectors interviewed license engineers, reviewed fire protection program documents, and conducted plant walk-downs to verify that suppression systems were capable of performing the safety function credited in the SAR, and/or the ISAS. Specifically, the inspectors performed the following activities:

• interviewed licensee engineers, reviewed event reports and maintenance WOs, and walked down the fire water tanks and fire water pump house to verify the licensee-maintained fire suppression systems;

• interviewed licensee engineers and maintenance personnel, reviewed the licensee's pre-fire plan, and conducted walk-downs in the CRDB and SBM-1001 to verify the licensee maintains firefighting equipment (e.g., fire extinguishers, fire risers) in designated locations; and

• walked down areas where water-based suppression was prohibited due to criticality or electrical hazards to verify that water-based suppression systems were not present.

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 SAR, or the ISAS. Specifically, the inspectors performed the following:

• interviewed licensee operators, engineers and maintenance personnel; reviewed impairments, procedures, and WOs; and conducted walk-downs and observed maintenance to verify that IROFS35 fire doors meet the license and ISA requirements; and

• interviewed licensee engineers and maintenance personnel; reviewed training, condition reports, and procedures to verify ventilation fire dampers met license and ISA requirements.

Fire Protection Program Elements (IP Section 02.06) 8

The inspectors reviewed selected fire protection program elements to verify compliance with the license requirements. Specifically, the inspectors completed the following activities:

• interviewed licensee engineers and reviewed training material and impairment records to verify that compensatory measures (e.g., a fire watch) were imposed when IROFS were impaired;

• reviewed records and conducted interviews to verify that site fire brigade training and drills were conducted in accordance with license requirements;

• interviewed licensee fire protection staff and the manager responsible for fire protection to verify the staffing level, training, and experience of the fire protection organization met license requirements;

• observed emergency lighting test in SBM 1005/1006 under WO 1000465232;

• reviewed the current and previous versions of the pre-fire plan, and conducted walk-downs in SBM-1001 to verify changes to the pre-fire plans were consistent with the license requirements and that the pre-fire plan matched conditions in the field; and

• reviewed memoranda of understanding (MOU) with the city of Eunice and city of Hobbs fire departments to verify that they were renewed periodically.

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 CAP entries, audits, and self-assessments:

• EV 120693, 123647, 127052, 137600, 140151, 140416, 140595, 140598, 140701, 140834, 140937, 141490, 142826, 142899, 143194, 143324

• ER-2013-2390; and

• fire protection audit 2020-A-09-015 and associated EVs.

RADIOLOGICAL CONTROLS 86740 - Inspection of Transportation Activities The inspectors evaluated select aspects of the licensees Transportation Activities program to determine whether the licensee has established and is maintaining an effective, management-controlled program; to ensure radiological and nuclear safety in the receipt, packaging, delivery to a carrier and, as applicable, the private carriage of licensed radioactive materials; and to determine whether transportation activities are in compliance with the applicable NRC 10 CFR Parts 20 and 71 regulations and Department of Transportation (DOT) (49 CFR Parts 171-178) transport regulations.

The inspectors examined the licensees procedures and shipment records and observed actual package preparations and operations to verify compliance with the regulations above.

Specifically, the inspectors reviewed or observed the following:

• receipt contamination surveys and physical inspections of 48Y cylinders on the uranium byproduct cylinder (UBC) storage pad; 9

• crane operations involving the handling of 48Y and 30B cylinders;

• radiological survey of Hitman 962/Trailer # L00024;

• shipping documentation for 72 drums solid waste/10 poly cubes of liquid waste;

• shipping documentation for radioactive-low specific activity (LSA) solid/liquid wastes for treatment/disposal; and

• shipment preparations of six truckloads of UF6 30B cylinders/overpacks.

Preparation of Packages for Shipment (IP Section 02.01)

The inspectors examined the licensees procedures and package preparations to verify compliance with federal regulations and licensee procedures LO-3-3000-01, Transport Planning and RW-3-1000-13, Shipping Radioactive and Mixed Waste. Specifically, the inspectors reviewed the following:

• shipping document package and final placarding/verifications for a shipment of six full 30B cylinders including their UX-30 overpacks;

• cylinder internal inspections/pressure test records (IROFS16a) in accordance with LO-3-1000-04, Cylinder Release for Use, Rev. 3; and

• cylinder external inspections including cylinder valve acceptance criteria in accordance with LO-3-2000-01, External Cylinder Inspection, Rev. 19.

Delivery of Completed Packages to Carriers (IP Section 02.02)

The inspectors examined the licensees procedures and shipment records and observed actual transport activities to determine that the licensee met package delivery regulations and Chapter 11.0 of the SAR. Specifically, the inspectors reviewed or observed the following:

• Shipping Manifest 0918-02-0003, Shipment of 72 Drums Radioactive-LSA-II, UN3321, Fissile Excepted (DAW), to Energy Solutions, dated 12/4/2020;

• Shipping Manifest 0918-02-0003, Manifest Tracking 019278840 JJK, Shipment of 10 Poly Totes of Radioactive Solutions for Treatment and Disposal, Radioactive-LSA-II, UN3321, Fissile Excepted D002/D007, to Energy Solutions, dated 10/28/2019; and

• Shipping Manifest 0918-01-0004, Manifest Tracking 019278841, Shipment of 10 Poly Totes of Radioactive Solutions for Treatment and Disposal, Radioactive-LSA-II, UN3321, Fissile Excepted, D002/D007, to Energy Solutions, dated 10/25/2019.

Receipt of Packages (IP Section 02.03)

The inspectors examined the licensees procedures to verify compliance with 10 CFR 20.1906 and Section 11.4 of the SAR. Specifically, the inspectors reviewed the following:

• LO-3-2000-01, Receipt and Shipping of Cylinders," Rev. 24;

• LO-3-2000-03, On-Site Handling of UF6 Cylinders, Rev. 14 for compliance with IROFS 36c/e; 10

• samples of incoming and outgoing radiological surveys for compliance with RP-4-1000, Radioactive Shipment Surveys; and

• records of internal inspections (IROFS 16a) for incoming empty cylinders completed in accordance with LO-3-1000-04, "Cylinder Release for Use, Rev. 3.

Records and Reports (IP Section 02.04)

The inspectors examined the licensees recordkeeping and reports to verify compliance with the regulations above, Chapter 11.0 of the SAR, and Section 6 of the QAPD. Specifically, the inspectors reviewed the following:

• Certificate of Receipt for Manifest 0918-01-0004, Manifest Tracking 019278841 for Disposal, dated 10/28/2019;

• Certificate of Receipt for Manifest 0918-01-0003, Manifest Tracking 019278840 JJK for Disposal, dated 10/28/2019;

• Nuclear Material Transaction Report Form 741, Manifest 0918-01-0003, dated 10/24/2019; and

• Special Nuclear Material Exemption Certification, dated 10/22/2019.

General License Requirements (IP Section 02.05)

The inspectors reviewed licensee package certifications utilized for shipment of radioactive material packages to verify compliance with 10 CFR 71, Subpart C, and Chapter 11.0 of the SAR. Specifically, the inspectors reviewed the following:

• Model UX-30 Certification Type B (U) F Fissile Package Design Certificate USA/9196/B (U) F-96, Rev. 34.; and

• Model 30B Certification Type AF Fissile Package Design Certificate USA/0411/AF-96, Rev. 12.

Management Controls (IP Section 02.06)

The inspectors reviewed the system of management controls for transportation activities to verify compliance with Chapter 11.0 of the SAR. Specifically, the inspectors reviewed the following:

• LO-4-2000-03, Inbound 30B and 48Y Release Desktop Guide, Rev. 9;

• 0023-BSH-2016-001, Package Design Safety Report for Package Design DN-30, Rev. 3; and

• LCTP-21-04, Management Assessment of UF6 Incident During Transport, Rev. 0.

Indoctrination and Training Program (IP Section 02.07) 11

The inspectors reviewed training and indoctrination documentation to verify compliance with Chapter 11 of the licensee application. Specifically, the inspectors reviewed:

• training records showing completion of the class titled "Transportation Radioactive Materials" for three UUSA employees involved in transportation of radioactive waste Quality Assurance Program (IP Section 02.08)

The inspectors reviewed the quality assurance documents to verify compliance with 10 CFR 71.137, Section 2.3.5.2 of the SAR, and the QAPD. Specifically, the inspectors reviewed:

• UX-30-OMM, Columbia Hi Tech, UX-30 Operation and Maintenance Manual, Rev. 1; and

• UX-30 Manual, Columbia Hi Tech, Manufacturers Practices to Insure Regulatory Compliance and Longer Useful Life, Rev. 0.

Audit Program (IP Section 02.09)

The inspectors reviewed the assessment reports to verify compliance with 10 CFR 71.137 and Section 11.5 of the SAR and Section 18 of the QAPD. Specifically, the inspectors reviewed:

• UUSA Audit 2021-A-02-003, Logistics and Transportation, dated April 9, 2021 Procurement and Selection of Packagings (IP Section 02.10)

The inspectors examined the licensees packaging, including those provided from a vendor and revised procedures and records to verify compliance with the federal regulations above, Section 11.2 of the SAR, and Section 14 of the QAPD. Specifically, for packaging that is used by the licensee to transport or to deliver licensed material to a carrier for transport, the inspectors reviewed the following:

• records associated with IROFS 16a cylinder internal inspections/pressure testing records in accordance with LO-3-1000-04, Cylinder Release for Use, Rev. 3; and

• Model 30B Certification Type AF Fissile Package Design Certificate USA/0411/AF-96, Rev. 12.

Preparation of Packages for Shipment (IP Section 02.11)

The inspectors examined the licensees package markings and documentation to verify compliance with applicable parts of the federal regulations above and Section 13 of the QAPD. Specifically, the inspectors reviewed the following:

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• LO-3-3000-01, Transport Planning, Rev. 25; and

• RP-3-5000-01, Radioactive Material Shipment Surveys.

Periodic Maintenance of Packagings (IP Section 02.12)

The inspectors examined the licensees records to verify compliance with applicable parts of the federal regulations above. Specifically, the inspectors reviewed the following:

• calibration records for torque wrenches and thread go and no-go gauges used on UF6 cylinders Records, Reports, and Notifications (IP Section 02.13)

The inspectors reviewed the licensees records and procedures for recordkeeping and reports to verify that a system is in place to verify compliance with the federal regulations and Chapter 11 of the SAR. Specifically, the inspectors reviewed the following:

• EV 140329, involved an error in calculating trace radionuclide content of solid low-level waste was discovered during database testing;

• EV 140435, involved improper removal of cylinder tamper indicating devices (TIDs) from System Applications and Products (SAP) computer database; and

• EV 144742, involved multiple issues including containers not listed in uranium accounts, TID accounting issues, TID on wrong cylinder in SAP, and multiple cylinders with TIDs applied in SAP that were no longer physically applied to the cylinder.

88045 - Effluent Control and Environmental Protection The inspectors evaluated selected aspects of the licensees environmental protection program to verify compliance with selected portions of 10 CFR 20, Part 70, and the facilitys SAR.

Program Implementation (IP Section 02.01)

The inspectors reviewed any significant changes to the effluent control and environmental protection program, discussed with the licensee any new unplanned releases or contamination identified, and screened the CAP in order to verify the environmental protection program was being implemented in compliance with license requirements. Specifically, the inspectors reviewed the following documents and/or performed the following activities:

• accompanied licensee environmental and radiological staff for demonstrations on use of operating exhaust stack particulate sampling equipment, use of operating perimeter ambient air particulate samplers; collection of sample media from the equipment, and analysis of the collected samples; and

• accompanied licensee environmental and radiological staff for demonstrations of collecting water and other environmental samples including vegetation sampling, soil sampling, storm water retention and detention basin sediment 13

sampling, and sanitary wastewater samples collected from the main sanitary lift station.

Training (IP Section 02.05)

The inspectors conducted interviews, reviewed training and indoctrination documentation, and directly observed activities of the environmental and radiological staff performing environmental activities, to evaluate the licensee's compliance with Section 11.3 of the SAR. Specifically, the inspectors reviewed the following:

• Department training records for environmental and radiological staff;

• Procedure TQ-3-0100-13, Training and Qualification Guidelines, Rev. 12

• UUSA Maestro Training Reference Guide, dated 2021;

• Procedure EN-3-2020-01, EN Air Sampling, Rev. 7; and

• Procedure EN-3-2020-02, EN Media Sampling, Rev. 8.

Effluent Monitoring (IP Section 02.09)

The inspectors observed effluent monitoring systems exhaust stacks from the upstream gaseous exhaust ventilation system (GEVS) systems, discussed calibration and maintenance with the radiological staff to verify compliance with the regulation and Chapter 9.0 of the SAR. Specifically, the inspectors completed the following activities:

• reviewed WO 1000449078, Alpha Monitor Cartridge Change, (air sampler media) for exhaust stacks UN-NEF-1001-562-1MA1 through UN-NEF-1005-562-1MA2, dated 12/21/2020;

• reviewed WO 1000466180, Alpha Monitor Cartridge Change, (air sampler media) for exhaust stacks UN-NEF-1001-562-1MA1 through UN-NEF-1005-562-1MA2, dated 7/6/2021;

• reviewed WO 1000466176, Alpha Monitor Cartridge Change, (air sampler media) for exhaust stacks UN-NEF-1001-562-1MA1 through UN-NEF-1005-562-1MA2, dated 3/3/2021; and

• observed air sampling conducted in accordance with procedure EN-32020-01, EN Air Sampling, Rev. 7.

Environmental Sampling (IP Section 02.13)

The inspectors reviewed environmental sampling related to ambient air, and sanitary sewer, to verify compliance with 10 CFR 20.1501 and Chapter 9.0 of the SAR. Specifically, the inspectors completed the following activities:

• walked down air and water environmental sample points including a GEVS air exhaust stack sampler/equipment, ambient air samplers located around the perimeter of the facility, several retention and detention basins for stormwater runoff/condensate from air conditioning, and the final sanitary lift station sampling location; 14

• walked down the I-Matic automatic low background (radionuclide) counting system located in the main laboratory and confirmed the presence of quality control standard sources: thorium 230 alpha source and a technetium beta source, as required by the operating procedure EN-3-3030-01;

• reviewed procedure EN-3-2020-01, EN Air Sampling, Rev. 7;

• reviewed procedure EN-3-2020-02, EN Media Sampling, Rev. 8;

• reviewed WO 1000449078, Alpha Monitor Cartridge Change, (air sampler media) for exhaust stacks UN-NEF-1001-562-1MA1 through UN-NEF-1005-562-1MA2, dated 12/21/2020;

• reviewed WO 1000466180, Alpha Monitor Cartridge Change, (air sampler media) for exhaust stacks UN-NEF-1001-562-1MA1 through UN-NEF-1005-562-1MA2, dated 7/6/2021; and

• reviewed WO 1000466176, Alpha Monitor Cartridge Change, (air sampler media) for exhaust stacks UN-NEF-1001-562-1MA1 through UN-NEF-1005-562-1MA2, dated 3/3/2021.

Radioactive Waste Classification, Characterization, and Storage (IP Section 02.15)

The inspectors reviewed documentation and records of facility activities and observed posting and labeling of storage areas and containers to verify compliance with the requirements of 10 CFR 61.55 and the Section 12.6.1.5 of the SAR. Specifically, the inspectors performed the following:

• walked down the liquid effluent collection and transfer system, the bulk storage tank, the multifunction decontamination train, the vacuum pump rebuild workshop and associated area to determine compliance with labeling of containers that hold radioactive waste solutions derived from equipment decontamination and refurbishment activities;

• reviewed records and conducted a walkdown of the bulk storage tank, the multifunction decontamination train, the vacuum pump rebuild workshop and associated areas to determine compliance with mass limits for IROFS55a and IROFS55b controls as described in the ISA Summary Section 3.5.12, and SAR Section 12.6.1.5.

INSPECTION RESULTS CAAS inaudibility not reported Severity Report Section Severity Level (SL) IV 88015 Non-Cited Violation (NCV) 07003103/2021003-01 Open/Closed The NRC inspectors identified a SL-IV NCV of the reporting requirements in 10 CFR 70.50(b)(2).

Description:

One July 20, 2021, during the 2021 annual CAAS maintenance, licensee employees identified that the CAAS was not clearly audible in room 242 of the Technical Services Building (TSB). This was documented in the licensee's CAP as EV 147490. On July 21, 2021, the licensee screened this event as not reportable because "Compensatory 15

measures which achieve an equivalent safety function were established within 24hrs following the identification of the alarms in the TSB not being clearly audible."

The CAAS is required by 10 CFR 70.24(a) and license commitments to mitigate the consequences of a criticality accident by ensuring that all personnel withdraw to an area of safety upon the sounding of the alarm. In 10 CFR 70.24 the CAAS is required to be "clearly audible". Employees conducting the tests could not hear the alarm and sound pressure readings taken while the CAAS was alarming were only about one decibel dB above those taken while the CAAS was off. Prior to the time of discovery no redundant equipment was available and operable. No other locations were identified where the CAAS was not clearly audible.

This issue is considered an isolated failure to report as no other examples of failures to report were found during this inspection, or recent inspections involving radiological protection or nuclear criticality safety.

Corrective Actions: On September 17, 2021, the licensee notified the NRC Headquarters Operations Officer in accordance with 10 CFR 70.50(b)(2); which is documented in EN55480, CAAS Alarm Not Clearly Audible.

Corrective Action

References:

This issue was entered into the licensees CAP as EV 148123.

Analysis: The regulations in 10 CFR 70.50(c)(1) require, in part, that "Licensees shall make reports required by paragraphs (a) and (b) of this section ... to the NRC Operations Center."

10 CFR 70.50(b) "Twenty-four hour report" requires, in part, that "Each licensee shall notify the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the discovery of any of the following events involving licensed material: ... (2) An event in which equipment is disabled or fails to function as designed when:

(i) The equipment is required by regulation or licensee condition to ... mitigate the consequences of an accident; (ii) The equipment is required to be available and operable when it is disabled or fails to function; and (iii) No redundant equipment is available and operable to perform the required safety function."

In this instance, the CAAS failed to function as designed as required by 10 CFR 70.50(b)(i) by failing to provide a clearly audible evacuation alarm in TSB room 242 as required by 10 CFR 70.24 to mitigate the consequences of an accident. In addition, the CAAS was required to be available and operable, both when the failure was found, and during any prior period of inaudibility; therefore, criteria (ii) of 10 CFR 70.50(b)(2) was met. At and before the time of discovery, no redundant equipment was available and operable to perform the required safety function of the CAAS in TSB room 242; therefore, criteria (iii) of 10 CFR 70.50(b)(2) was satisfied. Because all the criteria in 10 CFR 70.50(b)(2) were met, a report should have been made to the NRC in accordance with 10 CFR 70.50(b).

This failure to report had no actual or potential safety or security consequences. However, a failure to make a required report to the NRC does have regulatory significance. Per Enforcement Policy Section 2.2.1(c) Unless otherwise categorized in the violation examples contained in this Policy (i.e., Section 6.0), the severity level of a violation involving the failure to make a required report to the NRC will depend on the significance of and the circumstances surrounding the matter that should have been reported. the Agency will normally cite a licensee for a failure to report a condition or event if the licensee knew of the 16

information to be reported and did not recognize that it was required to make a report.

Section 2.3.2 "Non-cited Violation," of the Enforcement Policy states, in part, "If a licensee ...

has implemented a CAP that is determined to be adequate by the NRC, the NRC will normally disposition SL-IV violations... as non-cited violations (NCVs) if all the criteria in Paragraph 2.3.2.a. are met."

Enforcement:

Severity: Consistent with Section 6.0, Violation Examples, of the NRC Enforcement Policy the violation aligned with the SL-IV violation Example 6.9(d)(5) in that it involved a licensee failure to make a report required by 10 CFR 70.50(c)(1).

Violation: Contrary to the above requirements in 10 CFR 70.50, from July 21, 2021; to September 16, 2021, the licensee failed to notify the NRC of an event in which equipment failed to function as designed when, the equipment was required by regulation and licensee condition to mitigate the consequences of an accident, the equipment was required to be available and operable when it failed to function; and no redundant equipment was available and operable to perform the required safety function on and before the licensee's discovery of the condition.

This is a violation of 10 CFR 70.50(b); which is being documented as NCV 70-3103/2021003-01, "CAAS Inaudibility Not Reported," and is being opened and closed in this report.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.

• On August 12, 2021, the inspectors presented the Fire Protection and Operational Safety inspection results to Karen Fili and other members of the licensee staff.

• On September 16, 2021, the inspectors presented the NCS, Transportation and the 2020 Environmental follow-up inspection results to Karen Fili and other members of the licensee staff.

17

DOCUMENTS REVIEWED Inspection Type Designation Description or Title Rev. or Date Procedure 86740 Miscellaneous UUSA QAPD UUSA Quality Assurance Program Description Rev. 42a 86740 Miscellaneous UUSA SAR UUSA Safety Analysis Report Rev. 48 86740 Procedures Guide UUSA Maestro Training Reference Guide 2021 86740 Procedures LO-3-1000-04 Cylinder Release for Use Rev. 3 86740 Procedures LO-3-2000-01 Receipt and Shipping of Cylinders Rev. 24 86740 Procedures LO-3-2000-01 External Cylinder Inspection Rev. 19 86740 Procedures LO-3-2000-03 On-Site Handling of UF6 Cylinders Rev. 14 86740 Procedures LO-3-3000-01 Transport Planning Rev. 25 86740 Procedures LO-4-2000-03 Inbound 30B and 48Y Release Desktop Guide Rev. 9 86740 Procedures RP-3-5000-01 Radioactive Material Shipment Surveys 86740 Procedures RW-3-1000-13 Shipping Radioactive and Mixed Waste Rev. 15 86740 Procedures TQ-3-0100-13 Training and Qualification Guidelines Rev. 12 86740 Self- 2021-A-02-003 UUSA Audit 2021-A-02-003, Logistics and Transportation 04/09/2021 Assessments 88015 Corrective Action EV109638, NCS Related Corrective Action Items Documents EV143495, EV145944, EV145989, EV147419, EV147490, EV147499, EV147641, EV147960 88015 Corrective Action EV148087, Documents EV148104 Resulting from Inspection 88015 Engineering ESR-2021-074 CAAS Inaudible TSB Rm 242 Rev. 0 Evaluations 88015 Engineering NCS-CSA-006 Criticality Safety Analysis of the Product Vent Pump and Rev. 10 Evaluations Chemical Trap Set 88015 Engineering NSR-2011-010 Blending & Sampling System Rev. 0 18

Evaluations 88015 Engineering NSR-2015-043 Product Vent Pump and Chemical Trap Set (System 425) Rev. 0 Evaluations for AU1006 88015 Engineering NSR-2015-043 Product Vent Pump and Trap Sets - Assay 1006 Rev. 0 Evaluations 88015 Engineering NSR-2020-002 Product Pumping and Tails Trains (System 422, Assay 1, Rev. 4 Evaluations System 432, Assay 1, Cascades 1 through 8) and Spare Trains 88015 Engineering NSR-2020-02 SBM 1005 30B Stillage GEVS Piping Vents Rev. 0 Evaluations 88015 Engineering NSR-291-007 Blending & Sampling System Rev. 0 Evaluations 88015 Miscellaneous INTEGRATED SAFETY ANALYSIS

SUMMARY

Rev. 32b 88015 Miscellaneous NCS Walkthrough Schedule 88015 Miscellaneous E-NCS-CP NCS Criticality Engineer Demonstration of Continued Rev. 5 Proficiency 88015 Miscellaneous E-NCS-CP_QN_2021 NCS Criticality Engineer Demonstration of Continued Completed Proficiency 01/06/2021 88015 Miscellaneous E-NCS-QG Nuclear Criticality Safety (NCS) Engineer Rev. 5 88015 Miscellaneous EAP02 Emergency Action Plan for the Security Building Rev. 7 88015 Miscellaneous EAP05 Emergency Action Plan for the Cylinder Receipt and Rev. 7 Dispatch Building 88015 Miscellaneous EAP08 Emergency Action Plan for the Technical Support Rev. 7 Building (TSB) 88015 Miscellaneous GET-CBT General Employee Training by Computer Based Training 88015 Miscellaneous NCSI-21-0013 SBM-1005 PSC 06/07/2021 88015 Miscellaneous NCSI-21-0014 SBM-1005 UF6 Area 06/10/2021 88015 Miscellaneous NCSI-21-0015 SBM-1003 PSC` 06/19/21 88015 Miscellaneous NCSI-21-0017 CRDB GEVS Room 06/30/21 88015 Miscellaneous NCSI-21-0019 Mass Spec Rooms 1001/1003/1005 07/14/2021 88015 Miscellaneous NCSI-21-0020 Decontamination Workshop 07/23/2021 88015 Miscellaneous NCSI-21-0022 TSB CAAS 08/06/2021 88015 Miscellaneous NCSI-21-0023 HF monitors and DI solution storage areas in the CRDB 08/03/2021 and SBM1001/1003/1005 to exit anomalous condition 88015 Miscellaneous NCSI-21-0024 USM CAAS 08/19/2021 19

88015 Miscellaneous NCSI-21-0026 Cascade Halls SBM-1003 08/25/2021 88015 Miscellaneous NCSl-21-0021 LECTS Room 07/27/2021 88015 Miscellaneous NCSl-21-0025 Cascade Halls SBM-1001/1001X 08/19/2021 88015 Miscellaneous SBDV-2010-0029 Blending & Sampling Rig - Assays 1001 & 1002 - UF6 Rev. 1 Handling Area 88015 Miscellaneous SBDV-2011-0094 Blending & Sampling System - Assays 1001 & 1002 - Rev. 0 UF6 Handling Area 88015 Miscellaneous SBDV-2015-0031 Product Vent Pump and Trap Sets - Assay 1006 Rev. 0 88015 Miscellaneous SBDV-2016-0009 AU1002 Process Gas Piping; UF6 Handling Area and Rev. 0 Mass Spectrometer Room 88015 Miscellaneous SBDV-2019-0017 SBM-1005 30B Cylinder Stillage Utility Frames - GEVS Rev. 0 Drops 88015 Procedures CR-3-1000-03 NCS Weekly Walkthroughs and Periodic Assessments Rev. 16 88015 Procedures EG-3-3200-03 Safe By Design Attribute Verification Rev. 7 88015 Procedures QA-3-3000-36 Operation of the Innov-X Systems Delta Series X-Ray Rev. 4 Fluorescence Spectrometer 88015 Procedures RP-3-2000-04 Radiation and Contamination Surveys Rev. 15 88015 Procedures RP-3-4000-07 Portable Instruments Rev. 11 88015 Procedures TQ-3-0100-13 Training and Qualification Guidelines Rev. 12 88015 Work Orders WO 1000489860 SITE: CAAS Spurious Alarms 88015 Work Orders WO 1000505490 Site CAAS System: 0000-561 Discrepancies 07/22/2021 88020 Calculations CALC-C-00179 Seismic Qualification of Support Structures for IROFS11, Rev. 0 12, and IROFS43 88020 Calculations CALC-K-00015 Automatic Trip of the Autoclave Heater & Fan on Rev. 1 Autoclave High Internal Air Temperature (IROFS11) 88020 Calculations CALC-K-00016 Automatic Trip of the Autoclave Heater & Fan on High Rev. 0 Internal Pressure (IROFS12) 88020 Engineering 51-9058919-005 Louisiana Energy Services (LES) National Enrichment Rev .5 Evaluations Facility IROFS Failure Modes and Effects Analysis 88020 Engineering NEF-BD-11 Automatic Trip of the Autoclave Heater and Fan on Rev. 6 Evaluations Autoclave High Internal Air Temperature 88020 Engineering NEF-BD-12 Automatic Trip of the Autoclave Heater and Fan on Rev. 5 Evaluations Autoclave High Internal Air Pressure (Pressure Transmitter) 88020 Miscellaneous EV 146038, 145904, Various corrective action documents related to 08/12/2021 145835, 144688, operational safety 20

144687, 143321, 143082, 140675 88020 Miscellaneous EV 147727, 147735, EVs written as a result of the inspection Various 147737, 147748, 140834, 88020 Procedures MA-3-3400-01 IROFS1 Station Heater and Fan High Temperature Trip - Rev. 12 RTD Surveillance 88020 Procedures MA-3-3400-11 IROFS11 Autoclave Heater and Fan High Temperature Rev. 13 Trip - RTD Surveillance 88020 Procedures MA-3-3400-12 IROFS12 Autoclave Heater and Fan High Pressure Trip - Rev. 13 Pressure Detector Surveillance 88045 Miscellaneous QAPD UUSA Quality Assurance Program Description Rev. 42a 88045 Miscellaneous UUSA SAR UUSA Safety Analysis Report Rev. 48 88045 Procedures EN-3-2020-01 EN Air Sampling Rev. 7 88045 Procedures EN-3-2020-02 EN Media Sampling Rev. 8 88045 Procedures EN-3-3030-01 I-Matic Operation and Maintenance Rev. 4 88045 Procedures Maestro Guide UUSA Maestro Training Reference Guide 2021 88045 Procedures TQ-3-0100-13 Training and Qualification Guidelines Rev. 12 88045 Work Orders WO 000449078 Alpha Monitor Cartridge Change 12/21/2020 88045 Work Orders WO 1000466176 Alpha Monitor Cartridge Change 3/3/2021 88045 Work Orders WO 1000466180 Alpha Monitor Cartridge Change 12/21/2020 88055 Corrective Action EV 120693, EV CAP items review during the Fire Protection inspection Various Documents 123647, EV 127052, EV 137600, EV 140151, EV 140416, EV 140595, EV 140598, EV 140701, EV 140834, EV 140937, EV 141490, EV 142826, EV 142899, EV 143194, EV 143324 and ER-2013-2390 88055 Corrective Action EV 147727, EV CAP items resulting from the Fire Protection Inspection Various Documents 147735, EV 147737, Resulting from EV 147748, EV 21

Inspection 147765, EV 147790, EV 147791, EV 147792, and EV 147952 88055 Drawings LES-000-PID-691- Piping & Instrumentation Diagram Domestic Water (691), Rev. 4 001-01 Potable Water (692), Process Water (693), and Fire Protection Water (694) 88055 Engineering PMCR-2021-NEW- Requesting Quarterly (3M): Fire Brigade Truck & Trailer Changes 170 Vehicle Inspection 88055 Engineering 1039-SUB-0086 Fire Alarm System - Vesda Pipe and Fittings 01/21/2009 Evaluations 88055 Engineering NEF-BD-035 Fire-Rated Barriers Rev. 20 Evaluations 88055 Engineering NEF-BD-36a Limit Transient Combustible Loading in Uranic Areas Rev. 18 Evaluations 88055 Fire Plans FP-3-1000-05 Pre-Incident Plan Development and Control Rev. 10 88055 Fire Plans FP-3-1000-05 Pre-Incident Plan Development and Control Rev. 11 88055 Fire Plans FPE-REV-001 Fire Hazards Analysis for Urenco USA Rev. 21 88055 Miscellaneous Fire Protection Org Chart 06/24/2021 88055 Miscellaneous Hot Work Training Completion Dates 08/12/2021 88055 Miscellaneous Fire Brigade Qualified List 08/12/2021 88055 Miscellaneous Memorandum of Understanding Between the City of 06/15/2020 Eunice Police, Fire, and Rescue Services and Urenco USA 88055 Miscellaneous Memorandum of Understanding Between City of Hobbs 06/15/2020 Fire Department and Urenco USA 88055 Miscellaneous Fire Drill Completion Dates 08/12/2021 88055 Miscellaneous 2021-HWP-052 1005 UF6 Area Brazing 05/14/2021 88055 Miscellaneous 2021-HWP-083 07/22 88055 Miscellaneous GF001LP00100 Hot Work/Compensatory Fire Watch Initial Computer Rev. 5 Based Training 88055 Miscellaneous GF001LP00I00 Hot Work/Compensatory Fire Watch Initial Rev. 5 88055 Miscellaneous MM263TPE05I00 Maintain IROFS 35 (Fire Damper) Rev. 2 88055 Miscellaneous OBSCIROFSQC00I00 UUSA Operator Basic, Item Relied On For Safety Rev. 0 (IROFS) and Operating Requirements Manual (ORM) 88055 Operability Fire Impairment Tracking Log 08/12/2021 22

Evaluations 88055 Procedures FP-1-1000-01 Fire Loss Prevention Rev. 1 88055 Procedures FP-2-1000-01 Fire Protection Program Requirements Rev. 10 88055 Procedures FP-3-1000-02 Flammable and Combustible Material Control Rev. 15 88055 Procedures FP-3-1000-03 Fire Prevention During Welding, Cutting, and Other Hot Rev. 13 Work 88055 Procedures FP-3-1000-04 Fire System Impairments Rev. 20 88055 Procedures FP-3-1000-09 Plant Fire Brigade and Training Rev. 4 88055 Procedures FP-3-2000-03 IROFS35 Weekly Fire Door Inspection and Rev. 12 IROFS35/36a/36d Combustibles Control Inspection -

CRDB and ICC 88055 Procedures MA-3-2670-01 IROFS35 Fire Damper Inspections Rev. 7 88055 Procedures ORM 35 Fire-Rated Barriers Rev. 9 88055 Procedures ORM 36a Administratively Limit Transient Combustible Load (SBM, Rev. 11 ICC, and CRDB) 88055 Procedures TQ-3-0100-12-F-10 Training Approval Form for Incipient Fire Brigade Drill Rev. 3 88055 Procedures TQ-3-0100-12-F-10 Training Approval Form: Hot Work Fire Watch CBT Rev. 2 88055 Self- 2020-A-09-015 Fire Protection NQA-1 Audit Rev. 0 Assessments 88055 Work Orders WO 1000412880 1Y: FWPH Fire System Flow Test 05/27/2020 88055 Work Orders WO 1000438903 3M: FWPH Fire System Inspect. 10/22/2020 88055 Work Orders WO 1000438976 3M: Inventory Fire Brigade Trailer 88055 Work Orders WO 1000449359 1Y: FWPH Fire System Flow Tests 06/24/2021 88055 Work Orders WO 1000465862 1W: ICC IROFS36A COMBUST CONT INSP 08/10/2021 88055 Work Orders WO 1000466930 3M: Review Fire Impairments 88055 Work Orders WO 100465231 3M: Test SBM 5/6 Emergency Lights 05/23/21 88055 Work Orders WO1000465232 3M: Test SBM 5/6 Emergency Lights 23