ML21025A290
| ML21025A290 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 01/22/2021 |
| From: | Eric Michel NRC/RGN-II/DFFI/FFB2 |
| To: | Land R Framatome |
| References | |
| IR 2020004 | |
| Download: ML21025A290 (14) | |
Text
January 22, 2021 Dr. Ronald Land Site Manager Framatome Inc.
2101 Horn Rapids Road Richland, WA 99354-0130
SUBJECT:
FRAMATOME INC. - U. S. NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT NUMBER 70-1257/2020-004
Dear Dr. Land:
This letter refers to the inspections conducted from October 1, 2020, through December 31, 2020, at the Framatome Inc., Facility in Richland, Washington. During that period, the U. S.
Nuclear Regulatory Commission (NRC) completed routine, on-site inspections due to favorable conditions that existed at that time involving the novel coronavirus disease (COVID-19).
The enclosed report presents the results of the inspections, which were conducted through a combination of document reviews, interviews, and on-site observations. The inspectors reviewed activities as they relate to public health and safety, the common defense and security, and compliance with the Commission's rules and regulations, as well as the conditions of your license. The inspections covered the areas of safety operations and facility support. The findings were discussed with you and members of your staff at an exit meeting held on November 5, 2020.
Based on the results of these routine inspections, no violations of more than minor significance were identified.
Additionally, the inspectors implemented measures during the inspection period to support the determination of reasonable assurance that the public and the environment would be adequately protected from the hazards related to the operation of your facility. These compensatory measures included activities such as supplemental reviews of licensee-submitted reports (e.g., effluent reports, plant modification reports, and changes to the Integrated Safety Analysis Summary) and increased communications with your staff to discuss the status of plant operations. The compensatory measures did not constitute direct inspection and were intended to address the impact of the COVID-19 public health emergency on the agencys routine oversight program, particularly on the continuous engagement with your facility via periodic site visits and in-person interactions. These proactive actions were taken to obtain additional insights into the safe operation of the facility during the COVID-19 public health emergency.
The NRC will continue evaluating the guidelines and recommendations from federal and state authorities, along with the conditions of your facility, to determine how to best conduct inspections until normality can be achieved. In the interim, the NRC will maintain compensatory measures and frequent communications with your staff to discuss regulatory compliance matters and gather information to inform the decisions about future inspections.
R. Land 2 In accordance with Title 10 of the Code of Federal Regulations, Section 2.390 of the NRC's "Rules of Practice and Procedure," a copy of this letter and enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
Should you have any questions concerning these inspections, please contact Tom Vukovinsky of my staff at 404-997-4622.
Sincerely,
/RA/
Eric Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 70-1257 License No. SNM-1227
Enclosure:
NRC Inspection Report 70-1257/2020-004 w/
Attachment:
Supplemental Information cc w/ encl: Distribution via LISTSERV
ML21025A290 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI\PB2 RII:DFFI\PB2 RII:DFFI\TA RII:DFFI\PB1 RII:DFFI\PB2 NAME G. Goff T. Vukovinsky E. Stamm B. Adkins E. Michel DATE 1/13/2021 1/15/2021 1/14/2021 1/15/2021 1/22/2021 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO U. S. NUCLEAR REGULATORY COMMISSION REGION II INSPECTION REPORT Docket No.: 70-1257 License No.: SNM-1227 Report No.: 70-1257/2020-004 EPID No.: I-2020-004-0035 Licensee: Framatome Inc.
Facility: Richland Facility Location: Richland, Washington Dates: October 1 through December 31, 2020 Inspectors: B. Adkins, Senior Project Inspector (A.1)
G. Goff, Project Inspector (A.2)
E. Stamm, Technical Assistant (B.1)
Approved by: E. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Enclosure
EXECUTIVE
SUMMARY
FRAMATOME INC.
NRC Integrated Inspection Reports 70-1257/2020-004 October 1 through December 31, 2020 An on-site inspection was conducted by regional inspectors in the performance areas of safety operations and facility support. The inspectors performed a selective examination of licensee activities that were accomplished by interviews and discussions with licensee personnel and a review of facility documents.
Safety Operations
- No violations of more than minor significance were identified related to Plant Operations. (Paragraph A.1)
- No violations of more than minor significance were identified related to Fire Protection (Annual). (Paragraph A.2)
Facility Support
- No violations of more than minor significance were identified related to Emergency Preparedness. (Paragraph B.1)
Attachment:
Key Points of Contact List of Items Opened, Closed, and Discussed Inspection Procedures Used Documents Reviewed 2
REPORT DETAILS Summary of 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.
A. Safety Operations
- 1. Operational Safety (Inspection Procedure 88020)
- a. Inspection Scope The inspectors evaluated the operational safety of the facility in order to verify that the licensee operates the plant safely and in accordance with Title 10 Code of Federal Regulations (CFR) Part 70 and the License Application as incorporated by reference in Safety Condition S-1 of Materials License SNM-1227. The inspectors interviewed the operations manager and engineers and reviewed records associated with the UF6 Recertification facility to verify compliance with the License Application. The inspectors reviewed license requirements, the items relied on for safety (IROFS) database, criticality safety evaluations, and operating procedures associated with the UF6 Recertification facility to verify that the requirements for the process areas were consistent within the licensees documents. Specific to the UF6 Recertification facility, the inspectors evaluated IROFS 705, 706, 707, 708, and 709 to verify that they were being implemented as described in the Integrated Safety Analysis (ISA) and that the licensee was in compliance with the requirements Chapter 3 of the License Application.
The inspectors conducted a limited review of other areas including the UF6 cylinder -
receipt and storage building, scrap uranium recovery facility (SURF), and uranium dioxide (UO2) building to verify proper implementation of IROFS and management measures.
The inspectors performed field walkdowns of the UF6 Recertification facility with approved process and instrumentation drawings (P&IDs) and procedures to verify the field configurations were maintained in accordance with the configuration control requirements of the License Application. The inspectors also walked down the area to confirm the associated IROFS were present and evaluated that these engineered and administrative safety controls were capable of preventing or mitigating associated accidents/consequences as required by 10 CFR 70.62. The inspectors interviewed operators to verify that they were knowledgeable of administrative controls and limits as per licensee procedures.
The inspectors observed three IROFS-related surveillances to verify that the licensee was properly implementing management measures to ensure that IROFS were reliable and available to perform their intended safety function as required by 10 CFR 70.61(e) and 70.62. Specifically, the inspectors observed the following: (1) calibration check of level instrument transmitter (LIT)-34701 in the SURF (IROFS 239), (2) calibration check of radiation monitors in the UF6 cylinder receipt and storage building (IROFS 2903), and (3) verification of proper grease level in ammonium diurinate (ADU) calciner (IROFS 2207). The inspectors also evaluated the procedures contents with respect to operating limits and operator responses for upset conditions to verify that the limits needed to assure safety were adequately described in the procedures.
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The inspectors interviewed the training manager and reviewed training records for initial and continuing training programs to verify compliance with training requirements of Section 11.3.2 of the License Application. The inspectors reviewed operator qualification records for the UF6 Recertification facility to verify that the individuals were currently qualified on the systems and equipment to which they were assigned to operate and maintain.
The inspectors reviewed a sample of entries from the licensees corrective action program (CAP) created since the last operational safety inspection to verify that deviations from procedures and unforeseen process changes affecting nuclear criticality, chemical, radiological, or fire safety were documented and reviewed promptly, as required by Section 11.6.1 of the License Application. In addition, the inspectors reviewed the licensees corrective actions to verify they were adequate to address and resolve the issue(s) as required by Section 11.6.1 of the License Application. The CAP program entries reviewed are listed in the supplementary information section of the report.
b. Conclusion
No violations of significance were identified.
- 2. Fire Protection Annual (Inspection Procedure 88055)
- a. Inspection Scope The inspectors evaluated that the following aspects of the licensees fire protection program complied with the conditions of Chapters 7 and 11 of the License Application and were capable of precluding or mitigating the consequences of a fire.
Specifically, the inspectors observed that the licensee controlled transient combustibles and ignition sources in accordance with licensee procedures (see attachment). The inspectors walked down the Dry Conversion Facility (DCF); the UO2 Building; the Specialty Fuels (SF) Building; Warehouses 1, 2, & 3; parts of the Scrap Uranium Recovery Facility (SURF), parts of the Uranyl Nitrate Building (UNB), and parts of the Modular Extraction Recovery Facility (MERF) to verify that the licensee did not store more than 27 cubic feet of combustible materials in a restricted area longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and that ignition sources were not near any combustible materials as per IROFS 4502.
During the above walk-downs, the inspectors observed the material condition of the fire detection and suppression devices (heat detectors, smoke detectors, and sprinklers) to determine that none appeared to be impaired, degraded, or otherwise incapable of performing the intended safety function. For the sprinklers, the inspectors observed that at least 18 inches of clearance was maintained as per procedure. The inspectors reviewed documentation and observed water pressure gauges to verify that the water suppression systems could maintain adequate pressure throughout a discharge. The inspectors reviewed maintenance records (PMs) for both water-based and gaseous fire suppression systems to determine that the licensee maintained these suppression systems available, operable, and in proper material condition as per the License Application.
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The inspectors reviewed PMs for the last 12 months pertaining to fire protection equipment such as fire doors, fire dampers, fire walls, fire extinguishers, fire alarms, heat detectors, smoke detectors, and sprinklers to determine compliance with Chapter 11 of the License Application. The inspectors also performed walk-downs of fire extinguishers throughout the facilities referenced above to verify the state of readiness as per procedure.
During walk-downs the inspectors also observed that fire doors, fire dampers, fire walls, fire barrier penetration seals, oil collection systems, and electrical raceway fire barrier systems were maintained in a proper material condition. Specifically, the inspectors walked down the fire wall between Warehouse 2 and Warehouse 3 and the fire wall in the receiving bay of the UNB to determine compliance with Chapter 11 of the License Application. These two fire walls are the only fire walls that are designated as IROFS.
The inspectors also verified the proper location for administrative IROFS (postings/signage) which prohibited the use of water or permitted only the use of a mist due to criticality concerns as per the Integrated Summary Analysis (ISA). Inspectors also walked down the central fire alarm station to determine operability as per procedure (see the attachment).
The inspectors reviewed the logbook for compensatory measures put in place for out-of-service, degraded, or inoperable required fire protection equipment, systems, or features. The inspectors noted that there had not been any fire safety compensatory measures utilized within the last twelve months since none of the above conditions existed.
The inspectors reviewed corrective action entries identified during PMs or internal audits (see the attachment) to determine that the licensee was identifying problems and entering them into the corrective action program.
The inspectors reviewed required training for select individuals regarding the basic use of fire extinguishers. The inspectors noted that this training was administered as part of the required general employee training.
b. Conclusion
No violations of significance were identified.
B. Facility Support
- a. Inspection Scope The inspectors reviewed select aspects of Framatomes emergency preparedness program to verify compliance with sites License Application, Emergency Plan, Emergency Plan Implementing Procedures (EPIPs), and 10 CFR 70.
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The inspectors interviewed staff and reviewed records to verify that changes made to the Emergency Plan and within the facility were reviewed by the Emergency Preparedness (EP) organization as required. This included inspection to verify that the licensee had established controls to ensure that the Emergency Plan and implementing procedures were maintained up to date, including identifying when prior NRC approval is required for proposed changes to the program. This also included inspection to verify changes to the emergency preparedness program were coordinated with the appropriate offsite support groups and agencies, and that the licensee evaluated the startup of the new scrap uranium recovery facility and its impact on the emergency preparedness program. The inspectors also verified the licensees emergency call list was current and the source term and analysis utilized by the licensee for the emergency plan was maintained and current.
The inspectors reviewed a sample of the Emergency Plan Implementing Procedures and interviewed staff to verify that current copies of the EPIPs were readily available to members of the emergency management and response organizations and were maintained current in the appropriate field locations. The inspectors reviewed the content of the procedures to determine whether the procedures provided for the detection and proper classification of accidents, mitigation of the consequences of accidents, assessment of releases, protective actions recommendations, personnel accountability, notification and coordination, and authority for initiating evacuation alarms, and safe shutdown. The inspectors reviewed selected pre-emergency plans and walked down the associated buildings to determine whether nuclear criticality safety (NCS) precautions for firefighting were included in the emergency procedures; and areas in which firefighting restrictions exist because of NCS concerns were clearly posted as required. The inspectors reviewed selected pre-emergency plans to determine whether they were current, available at required field locations, and reflect any special considerations such as unique chemical hazards or areas where water must be excluded for firefighting due to NCS concerns as required.
The inspectors reviewed training records and interviewed licensee staff regarding emergency preparedness training that occurred since the last inspection. Interviews included emergency directors, security personnel, incident commanders, and other emergency response personnel with responsibilities associated with the Emergency Operations Center and emergency response activities. The inspectors conducted the interviews and reviews to verify that the licensee provided position specific training and training for personnel that utilize emergency equipment in the field as required by the Emergency Plan and EPIPs, and to verify that that those individuals were qualified as required. The inspectors reviewed training material to verify that the licensee provided training for postulated emergency situations consistent with the Emergency Plan, and that training for offsite personnel included special instructions and orientation tours as required by the Emergency Plan. The inspectors reviewed rosters and other documentation to verify that the licensee maintained appropriate staffing of trained emergency personnel for all shifts in accordance with the Emergency Plan.
The inspectors reviewed the written agreements with off-site support agencies to verify that Memorandums of Understanding (MOUs) between the off-site organizations and the licensee were maintained up to date as required by the Emergency Plan.
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The inspectors interviewed off-site organization representatives and reviewed records to verify that the licensee and off-site support agencies maintained an understanding of the written agreements, and that the licensee invited the Richland Fire Department for training and drill participation as required by the Emergency Plan.
The inspectors reviewed records and interviewed staff to verify that the licensees program ensures that emergency exercise objectives and scenario details are kept confidential from participants. The inspectors reviewed drill packages and interviewed staff to verify that the licensees emergency exercises have a credible, technically correct, and challenging scenario and involve a critical and candid assessment or critique of the response. The inspectors reviewed drill schedules to verify that required drills and exercises were conducted within the timeframe required by the Emergency Plan and EPIPs. The inspectors reviewed corrective actions and interviewed staff to verify that items identified during critiques/events were being captured and addressed in the corrective action program.
The inspectors observed the storage of emergency equipment in the central guard station, Emergency Operations Center (EOC) equipment room, EOC equipment shed, and Engineering Laboratory Office building to verify that the equipment was maintained in a ready state as required by the Emergency Plan. The inspectors reviewed the accountability procedure and observed onsite and offsite rendezvous facilities or areas, the EOC, and the alternate EOC to verify that pre-determined accountability muster locations were accessible and contained operable and adequate communications and other equipment as specified in the Emergency Plan.
The inspectors reviewed licensee audit records to verify that the licensee conducted audits in the area of emergency preparedness as required by the Emergency Plan. The inspectors reviewed audit records and corrective actions to verify that findings and recommendations were addressed in the corrective action program as required.
The inspectors reviewed documentation of events that occurred since the last EP inspection, which required the implementation of the Emergency Plan, to verify that problems or deficiencies associated with the Emergency Plan or EPIPs were documented, investigated, and corrected as required.
b. Conclusion
No violations of significance were identified.
C. EXIT MEETING The inspection scope and results were presented to Dr. Ron Land, Site Manager, and other members of the licensees staff on November 5, 2020. Proprietary information was discussed but not included in the report.
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SUPPLEMENTAL INFORMATION
- 1. KEY POINTS OF CONTACT Name Title J. Bourgeois Supervisor, Instrument Technicians and Electricians J. Deist Emergency Preparedness Manager W. Doane Nuclear Criticality Safety Manager S. Dunfee Industrial Hygienist D. Durham Supervisor, Carpenters, Painters, & Air Balance M. Durst Chemical/Electrical Engineering Supervisor K. Hayes Maintenance Millwright J. Henn Supervisor, Millwrights and Pipefitters L. Hope Training Manager J. Kreitzberg Nuclear Criticality Safety Engineer R. Lansing Engineering Specialist Level IV (Design Engineer Specialist)
P. Lee SAP Coordinator for Maintenance C. Manning Licensing Manager T. Tate ESH&L Manager S. Till Recertification Operator S. Wright Industrial Health & Safety Manager
- 2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED None
- 3. INSPECTION PROCEDURES USED 88020 Operational Safety 88050 Emergency Preparedness 88055 Fire Protection Annual
- 4. DOCUMENTS REVIEWED Records:
Operational Safety 30B UF6 Cylinder Recertification Record Follower Card Cylinder No. TL130B030, 10/26/20 Fire Protection American Nuclear Insurers, nuclear liability insurance inspection for fire: 2020-0011-audit Framatome General Inspectorate inspection: 2019-956 and 2019-957 (Assessment)
Inspection, Testing, and Maintenance of Wet Pipe Sprinkler Systems, 02/12/2020 Maintenance Order - 11482830, Repairs to Doors #66 & #67 UO2 RM 100, November 2020 Pre-Job Briefing 15915, for Maintenance Order 11482830, 11/04/2020 Attachment
Work Orders Fire Protection CG06P011, Fire Alarm Building Evac - 12 MO, 03/01/2019 CG06P012, Fire Hydrant Flow Test - 12 MO, 04/01/2020 CG06P014, Fire Wall Inspection - 6MO, 04/01/2020, 10/01/2020 CG06P015, Fire Extinguishers - 1 MO, 09/01/2020 CG06P019, Fire Sprinklers - 3MO, 02/01/2020, 05/01/2020, 08/01/2020, PM004445, Dry Chem & UO2 Fire Sys - 6 MO, 01/01/2020, 01/30/2020 (special),
07/01/2020 PM004949, NOVEC Fire Suppression - 6 MO, 01/01/2020, 07/01/2020 PM005105, Suprt Bldg Est3/Heat/Pull - 5Y EL Emergency Preparedness E08-03-5.1, After Action Reports - various dated October 20, 2020 EP Curricula Contents - various dated November 4, 2020 EP Training Records - various dated November 4, 2020 JMD: 20:007, Semi-Annual Criticality Evacuation Drill Results, dated June 19, 2020 JMD: 20:012, Semi-Annual Criticality Evacuation Drill Results, dated October 12, 2020 Procedures:
Operational Safety SOP-40259, Chemical Operations - UF6 Cylinder Washing UF6 Cylinder Wash Operation, Version 42 SOP-40315, Chemical Operations - UF6 Cylinder Recertification Testing and Inspection of UF6 Recertification Testing and Inspection of UF6 Cylinders, Version 22 Standard Work Instruction (SWI) Transportation and Logistics - UF6 Cylinder Pad Operation Transfer and Storage of UF6 Cylinders, Version 9 Fire Protection MCP-30029, Housekeeping, Version 4.3 MCP-30031, Flammable and Combustible Liquids/Solids Storage & Handling, Version 12.0 MCP-30039, Hot Work Procedure, Version 12.0 SOP-41044, Designated Hot Work Area Requirements Procedure, Version 7.0 Emergency Preparedness E08-01-1.0, Emergency Plan, Version 15.0 E08-02-1.0, Quick Reference Section, Version 17.0 E08-03-1.1, Classifying an Emergency, Version 7.0 E08-03-3.1, Plant Emergency Director, Version 9.0 E08-03-3.1A, Interim Plant Emergency Director, Version 2.0 E08-03-8.5, Emergency Equipment Lists, Version 14.0 E08-03-8.12, Relocating the Emergency Operations Center, Version 2.0 E08-03-8.13, Criticality Alarm, Version 3.0 2
Condition Reports Written as a Result of the Inspection:
Operational Safety CR-2020-2528 Fire Protection CR-2020-2492 Condition Reports Reviewed:
Operational Safety CR-2019-3961, CR-2020-1612, CR-2020-1436, CR-2020-1843 Fire Protection CR-2020-011, CR-2019-956, CR-2019-957, CR-2020-1528, CR-2020-3290, CR-2020-1179 Emergency Preparedness CR 2020-1306, CR 2020-2224, CR 2020-2260, CR 2020-2392 Other Documents:
Operational Safety NCS Infraction 20-014, Evaluation of Reportability for NCS Infraction 20-014 (CR 2020-1612), 08/17/20 WO13444836, C005P001 CYL REC SUMPPMP & LEVEL 6 MO OPUR, 01/16/20 WO13444841, C090P021 CALCINER L2 LUBRICATE 1 MO MWH2, 01/20/20 WO13482058, C270P008 LEVEL DETECT LIT-34701 1 YR IN, 11/4/20 WO13482355, ASSAY UF6 CYL (WEST), 11/04/20 WO13482450, ADU CALCINER PM C090P021, CALCINER L2 LUBRICATION 1 MO PM, 11/02/20 Portfolio User Curriculum Status Report for User ID 51045, 11/03/20 Fire Protection AID-10430, Operator Aid / Manufacturing Engineering Design and Drafting Guide, Version 10.0 AREVA Fire Barrier Variances, 01/15/2010 Drawing, EMF-606,747, Fire Alarm System Heat Detector/Detection & Pull Stations Location Plan, various buildings, Revisions 1, 2, 3, 5, 6, 7, 8, 11,15, 17, 18, 19, 22, 28, 29 Drawing, EMF-608,610, Horn Rapids Road Site Arrangement Fire & Water Supply, Revisions 0 & 25 E04-NCSS-G06, Fire Prevention and Firefighting, Version 29.0 E12-03-031, Fire Extinguisher Inspections, Version 4.0 E14-02-006, Facility Support Storage Building Fire Hazards Analysis, Version 4.2 E24-01-001, Fire Hazards Analysis - Horn Rapids Road Site, Version 6.0 E24-01-106, Fire Hazards Analysis - Scrap Uranium Recovery Facility, Version 1.0 3
E24-01-199, Fire Hazards Analysis - Misc Facilities with SNM and Radiological Hazards, Version 6.0 Fire Damper and Door PM/s List IROFS Database - IROFS 4536, IROFS 4536.10, IROFS 4536.20 Organizational Chart - EHS&L Organizational Chart - Plant Engineering, Technical Support & Maintenance Spreadsheet of Fire Alarm PMs Emergency Preparedness 2020 Annual EP Orientation for Offsite Agencies and Nearby Neighbors Accountability Roll Call List - dated November 3, 2020 AID-10810 - 1.0 - Accounting for Personnel at Staging Area V, Version 1.0 Audit 19:87, US Fuel, EHS&S Richland, WA. Internal Audit on Emergency Preparedness Program, dated October 17, 2019 Audit 20:55, US Fuel, EHS&S Richland, WA. Internal Audit on Emergency Preparedness Program, dated 10/12/2020 E08-04-1.0, Letters of Agreement, Version 5.2 E08-04-2.2, Memorandum of Understanding between Framatome Inc. and Kadlec Regional Medical Center, dated August 2018 E08-04-2.4, Memorandum of Understanding between Framatome Inc. and U.S. Department of Energy, Richland Operations Office, dated August 2018 E08-04-2.9, Memorandum of Understanding between Framatome Inc. and Benton County Emergency Services, dated August 2018 E08-04-2.12, Memorandum of Understanding between Framatome Inc. and Richland Fire Department, dated August 2018 E08-05-016, Pre-Emergency Plan, Warehouse Bays 1-3, Version 1.0 E08-05-2.1, Pre-Emergency Plan, U02 Building, Version 2.0 E08-05-2.4, Pre-Emergency Plan, Engineering Laboratory Office (ELO) Building, Version 3.0 E08-05-2.20, Pre-Emergency Plan, Scrap Uranium Recovery Facility, Version 1.0 HRR-EP-100004, Interim Plant Emergency Director Training HRR-EP-100026, Accountability and Staging Area Training HRR-EP-200002, Hazardous Material Spill and Decontamination HRR-IND-700007, EP - B-W Emergency Event 7/15/2009 Brief, dated June 2010 WO 13467824, PM004493 Telephone Test 3 Mo Safe, dated October 5, 2020 WO 13478588, PM00091 Emergency Reposit 1 Mo Safe, dated November 2, 2020 4