ML23202A202
| ML23202A202 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 07/24/2023 |
| From: | Eric Michel NRC/RGN-II/DFFI |
| To: | Stephens L Framatome |
| References | |
| IR 2023002 | |
| Download: ML23202A202 (1) | |
Text
July 24, 2023 Mr. Lance Stephens Site Manager Framatome Inc.
2101 Horn Rapids Road Richland, WA 99354
SUBJECT:
FRAMATOME-RICHLAND - CORE INSPECTION REPORT 07001257/2023002
Dear Mr. Stephens:
This letter refers to the U.S Nuclear Regulatory Commission (NRC) inspection activities conducted from April 1 to June 30, 2023, for the Framatome-Richland fuel facility. On April 26 and June 15, the results of the inspections were discussed with you and other members of your staff. The results of the inspections 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. To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the public without redaction.
Sincerely, Signed by Michel, Eric on 07/24/23 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
ML23202A202 x Non-Sensitive x Publicly Available x SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI NAME C. Taylor G. Goff E. Michel DATE 07/21/2023 07/24/2023 07/24/2023 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07001257 License Number: SNM-1227 Report Number: 07001257/2023002 Enterprise Identifier: I-2023-002-0065 Licensee: Framatome Inc.
Facility: Framatome-Richland Location: Richland, WA Inspection Dates: April 24 to 26, 2023 June 12 to 15, 2023 Inspectors: L. Cooke, Fuel Facilities Inspector G. Goff, Fuel Facilities Inspector N. Peterka, Senior (Sr.) Fuel Facility Project Inspector T. Shewmaker, Fuel Facilities Inspector (trainee)
P. Startz, Fuel Facilities Inspector C. Taylor, Sr. Fuel Facility Project Inspector Approved By: Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a core inspection at Framatome Inc., 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 during this inspection.
Additional Tracking Items Type Issue Number Title Report Status Section Unresolved URI 07001257/2022-004-02 MURS Furnace Electrical 88072 Open Issue (URI) Hazard 2
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 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 88020 - Operational Safety The inspectors evaluated selected aspects of the licensees operational safety program to verify compliance with selected portions of Title 10 of the Code of Federal Regulations (10 CFR) 70 including 70.61, 70.62, Chapter 11, Management Measures, of the facilitys license application, 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/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 nuclear criticality safety (NCS), fire protection, and chemical safety based on the information provided in the integrated safety analysis summary. 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:
UO2 - UF6 cylinder washing (combine w/ADU) - systems 065 and 070 -
accident sequences: 065-201, 065-211, 065-214, 065-217, 065-1.1, 065-1.2, 065-1.4, 065-1.5, 065-1.5.1, 065-1.6, 065-1.7 UO2 - ADU (combine w/cylinder washing) - systems 080 and 090 - accident sequences: 080-3.22, 080-3.23, 080-4.1, 080-4.18, 080-4.19.1, 080-4.19.2, 080-6.3, 090-6.4, 090-6.5.2, 090-9.1, 090-10.1, 090-10.2, and 090-10.3 UO2 - storage & lube press feed - systems 350 and 360 - accident sequences:
322-2.1.4, 360-4.2, and 120-3.1 3
Review of Safety Controls and Related Programs (IP Section 02.02)
The inspectors reviewed information related to administrative, engineered, and passive 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:
IROFS 104, administrative control (AC)
IROFS 229, active engineered control (AEC)
IROFS 230, AEC IROFS 243, AEC IROFS 317, passive engineered control (PEC)
IROFS 403, PEC IROFS 736, AEC IROFS 803, AEC IROFS 805, AC IROFS 806, AEC IROFS 808, AEC IROFS 819, AEC IROFS 831, AEC IROFS 1051, AEC IROFS 1505, PEC IROFS 1508, PEC IROFS 2202, enhanced administrative control (EAC)
IROFS 2204, AEC IROFS 2205, EAC IROFS 2211, AEC IROFS 2213, EAC IROFS 2230, PEC IROFS 2231, PEC IROFS 2348, PEC IROFS 3503, AC IROFS 3506, AEC IROFS 3507, PEC IROFS 3510, AEC IROFS 4502, AC IROFS 4503, AC IROFS 6129, AEC IROFS 6213, AEC 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 license application. This review was performed to verify that selected safety controls or IROFS were present, available, and reliable to perform their safety function and 4
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 implementation of management measures for IROFS reviewed to include procedures, surveillances, functional testing, calibrations, corrective actions, and training reviewed implementing procedures for IROFS (see Documents Reviewed section) reviewed drawings for the ADU area, BLEU 45-gallon drum tumbler station, and the SURF raffinate treatment TK-361A/B, TK-362 (see Documents Reviewed section) observed maintenance/functional testing of:
o IROFS 229 o IROFS 230 o IROFS 243 o IROFS 2348 interviewed licensee personnel and reviewed the screening process for determining IROFS 243 was degraded reviewed the corrective action for degraded IROFS 243 reviewed management control procedures and standard operating procedures for the systems identified in section 02.01 (see Documents Reviewed section) reviewed E-14-01-007, Hazards Analysis - UO2 ADU Conversion Facility and Miscellaneous Ancillary Systems reviewed the following nuclear safety analyses:
o E04-NCSA-065, Cylinder Wash Operations o E04-NCSA-080, ADU Uranium Recovery o E04-NCSA-090, UO2 Powder Production o E04-NCSA-163, Industrial Waste Water Treatment Facilities 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 license application. Specifically, the inspectors conducted the following:
reviewed monthly NCS audits from January 2022 through April 2023 (see Documents Reviewed section) reviewed condition reports (CRs) related to the ADU, cylinder wash, storage and lube press feed systems (see Documents Reviewed section) reviewed qualification status of operators responsible for implementing the selected IROFS for ADU, cylinder wash, storage and lube press feed systems reviewed qualification status for a sample of operators on duty June 12 and June 13, 2023 reviewed management changes in the operations department and the qualification requirements versus personnel qualifications reviewed maintenance records and work orders for selected IROFS (see Documents Reviewed section) 7
reviewed justification for continued operation under compensatory measures: JCO 2022-003, 2022-004, and 2022-005 reviewed CRs for selected IROFS (see Documents Reviewed section) interviewed the operations manager regarding safety, responsibilities of staff, safety conscious work environment, and employee assistance program observed daily maintenance planning meetings observed daily operations plan-of-the-day meetings FACILITY SUPPORT 88051 - Evaluation of Exercises and Drills The inspectors observed and evaluated the licensees graded biennial exercise conducted on April 26, 2023, as well as briefings and critiques involving both onsite and offsite participants, to verify compliance with 10 CFR 70.22(i)(3)(xii) and the emergency plan. The scenario involved a leak at a large ammonium hydroxide tank which resulted in a chemical spill that accumulates in the spill basin, responders dispatching an entry team, and consideration of protective actions downwind of the event.
Exercise Planning (IP Section 02.01)
The inspectors reviewed the emergency exercise scenario, discussed the exercise objectives with licensee personnel, observed controller meetings, and walked down the plant areas before the exercise to verify compliance with the emergency plan, emergency plan implementing procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors reviewed or observed the following:
the frequency of exercises conducted by the licensee the scenario as it related to probability for occurrence at Framatome and to testing all elements of the emergency plan no pre-staging of equipment in preparation for the exercise duties and responsibilities for exercise personnel including controllers, evaluators, and observers the controllers' meeting for the emergency exercise the objectives of the exercise and the expectations from responders the post-drill critique for the emergency exercise Exercise Execution and Emergency Plan Implementation (IP Section 02.02)
The inspectors observed the initiation of the emergency exercise, the activation of the emergency operations center (EOC) and plant emergency organization, classification of the event, notification of offsite response organizations, establishment of the incident command post, implementation of field response teams, and reviewed onsite and offsite communications, releases and notifications to verify compliance with the emergency plan, emergency plan implementing procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors observed and reviewed the following:
the licensees analysis of plant conditions including assessment and classification of the accident scenario within the allowable time limits staffing for all EOC/emergency organization positions 7
protective action recommendations implemented by the EOC/emergency organization drafting of offsite notifications including a review of content and time of issuance onsite communication to occupational workers as it related to protective action recommendations occupational workers participation in protective actions and the process to conduct personnel accountability press release approval and issuance emergency director control of the EOC/emergency organization drill dose assessor use of dose software response coordinators recommendations regarding conditions for terminating the event and restarting normal operations recovery and re-entry recommendations implemented by the EOC/emergency organization members of the licensees emergency response team assembly at designated assembly areas and the arrival of offsite emergency responders to include the Richland Fire Department incident commander response to emerging situations to address the exercise scenario and meet the exercise objectives the incident commander command and control of the emergency response team and coordination of actions with offsite emergency responders Critiques, Exercise Control, and Identification and Resolution of Problems (IP Section 02.03)
The inspectors observed the staff critiques of the emergency exercise and reviewed the licensees related corrective action program entries to verify compliance with the emergency plan, emergency plan implementing procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors reviewed and observed the following:
critiques conducted by the licensee in which both licensee participants and offsite responders provided comments discussions pertaining to the satisfying of all objectives of the emergency exercise documented deficiencies identified during critiques including items planned for entry into the licensees corrective action program INSPECTION RESULTS No issues were identified.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On April 26 and June 15, 2023, the inspectors presented the inspection results to Lance Stephens and other members of the licensee staff at an exit meeting.
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DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88020 Calculations Wastewater Treatment JCO 12/12/2022 Calculations LIMS Analytical Services Layout for 12/12/2022 596660 Miscellaneous Liquids LIMS Analytical Services Layout for 12/12/2022 596685 Miscellaneous Liquids Corrective CR-2022- Various Various Action 2106 CR-Documents 2022-3171 CR-2022-3238 CR-2022-3298 CR-2023-068 CR-2023-1186 Corrective CR-2023- Degraded IROFS-243 06/12/2023 Action 1466 Documents Resulting from Inspection Drawings CSA-611270 Scrap UN Recovery Fac Raffinate Revision 0 Treatment TK-361A/B, TK-362 Process & Inst Diagram CSA-614931 ADU Area and BLEU 45-Gallon Revision 0 Drum Tumbler Engineering E-14-01-007 Hazards Analysis - UO2 ADU Version 30 Evaluations Conversion Facility and Miscellaneous Ancillary Systems E04-NCSA- UF6 Cylinder Washing Operation Version 065 13.0 E04-NCSA- ADU Uranium Recovery Version 080 25.0 E04-NCSA- UO2 Powder Production Version 090 18.0 E04-NCSA- Industrial Waste Water Treatment Version 163 Facilities (IROFS 2348) 36.0 JCO-2022- ARF Detector Replaced with Lab 12/12/2022 003 Analysis JCO-2022- Batch Process for ARF Bypass 12/14/2022 004 JOC-2022- Cylinder Recertification Ignore 12/15/2022 005 714 Alarm Miscellaneous Print out of pressure transmitter 06/14/2023 replacements since CY 2020 8
88020 Miscellaneous LU 2189 30B Cylinder Recertified 05/2023 30B Cylinder Recertification 05/30/2023 Follower Card Wash and Valve Follower for 06/12/2023 Cylinder LU 1122 E-15 ARF and Industrial Waste Water Revision 2.14 Treatment System 21 E15-01-2.9A UO2 Building Revision 20 FRM-E12- Justification of Continued 12/14/2022 01-007-A - Operation Under Compensatory JCO #2204 Safety Measures (E12-01-007)
Procedures E-12-01-007 Justification for Continued Revision 8 Operation Under Compensatory Safety Measures E04-05-01 Nuclear Criticality Safety Version Standards 19.0 E04-NCSS- NCS Guide Rules and Generic Revision G01 Program Regulations 24 E12-03-058 Incident Investigation/Corrective Version 5.0 Action Audit EO4-NCSS- Fire Prevention and Firefighting Revision G06 32 MCP-30324 Richland Procedure Writers Guide Version 16.0 MCP-30325 Instrument Repetitive Version Maintenance (IRM) 19.0 MCP-30340 Essential Material Class I: 45- Version 9.0 Gallon Powder Containers MCP-30383 Preventive Maintenance Version 6.0 MCP-30448 Cylinder Wash Controls Design Version 8.0 Description MCP-30455 UNH Powder Dissolution (System Version 120) Controls Design Description 11.0 MCP-30488 UO2 Pellet Dissolution (System Version 4.0 190) Controls Design Description MCP-31334 Ortec and Mirion Automated Version 1.0 Assay Systems SOP-40228 Uranium Conversion and Version Recovery Operation Rules 24.0 SOP-40233 Blending Powder Additives into Version NO2 Powder Drums 18.0 SOP-40234 Dry Powder Blending, Handling Version and Labeling of Poisoned 45- 16.0 Gallon Drums and Safe Batch Containers SOP-40259 UF6 Cylinder Wash Operation Version 46.0 9
SOP-40315 Recertification Testing and Version Inspection of UF6 Cylinders 26.0 SOP-40486 Richland Operations, General Version Rules 39.0 SOP-40520 UO2 (Room 104A) Drum Tumbler Version and Bucket Tumbler Operation 13.0 SOP-40531 Blending Powder Additives into Version 45-gallon Powder Drums in Line 6 13.0 SOP-40789 Work Order Instructions Version 20.0 SOP-40791 Maintenance Work Permit (MWP) Version
& Pre-Job Briefing (PJB) 20.0 SOP-40841 Preventive Maintenance (PM) Version 12.0 SOP-40920 Items Relied on For Safety Version 9.0 (IROFS) and Equipment Essential to Safety SWI-50235A Operating the Bucket Tumbler Version 2.0 Self- E04 NCS Monthly Audits Various Assessments 202201, 202202, 202303, 202204, 202205, 202206, 202207, 202208, 202209, 202210, 202211, 202212, 202301, 202302, 202303, 202304 Work Orders 13561202 CG81P003-008 BAR BT CART Revision and 1YR MWHZ 10.0 13561203 13575784 C350I001 SCALE PWDR Revision STORAGE 1Y CAL IN 2.0 13587704 C120P001 UNH Revision OVERFLOW/VENTS/DOOR 6MO 12.0 PF 13602765, CG06P001 FIRE SAFETY Revision 135987091, INSPECTION 1MO OPCH 10.0 13594932, and 13591011 10
13603015 C360P003-0001 TUMBLR DRUM Revision and DRAIN 1Y OPCH 1.0 13556439 13605950 C350P002 PWDR STRG MOIST Revision PROTECT 6MO IN 3.0 13606011 C490I010 NIMS SCALE WIT- Revision 60005 6 MO IN 2.0 13606266 C350P001 RACKS POWDER Revision STORAGE 1Y MW 2.0 13606439 CG81P002-0009 Barrel Restrain Revision and Bars 1Y EL 10.0 13578582 C080I016 TEMP SENSOR TT-16701 1 YR 05/09/2021 (IROFS IN 6213)
C080I016 TEMP SENSOR TT-16701 1 YR 11/16/2021 (Manual IN Call) (IROFS 6213)
C080I017 TEMP SENSOR TT-16801 1 YR 05/22/2022 (IROFS IN 6213)
C080I017 TEMP SENSOR TT-16801 1 YR 05/23/2023 (IROFS IN 6213)
C080I017 TEMP SENSOR TT-16801 1YR 05/09/2021 (Manual IN Call) (IROFS 6213)
C080I017 TEMP SENSOR TT-16801 1YR 11/16/2021 (Manual IN Call) (IROFS 6213)
C080I018 TEMP SENSOR TT-16901 1 YR 05/23/2023 (IROFS IN 6213)
C080I018 TEMP SENSOR TT-16901 1 YR 05/22/2022 (IROFS IN 6213)
C080I018 TEMP SENSOR TT-16901 1 YR 11/16/2021 (Manual IN Call) (IROFS 6213)
C080I018 TEMP SENSOR TT-16901 1 YR 05/09/2021 (Manual IN Call) (IROFS 6213) 11
C080P016 ADU IX HIGH TEMP. SHUTOFFS 08/13/2022 (IROFS 12MO IN 6213)
C080P016 ADU IS HI TEMP SHUTOFF 08/31/2021 (IROFS 12MO IN 6213)
C080P016 ADU IX HIGH TEMP. SHUTOFFS 08/31/2020 (IROFS 12MO IN 6213)
C080P016 IROFS TANK TK 156 ION 05/28/2021 (Manual EXCHANGE COLUMN Call) (IROFS 6213)
C090I002 HYGROMETER CAL-DROP-1 Y2 07/12/2022 (IROFS CAL IN 2204)
C090I002 HYGROMETER CAL-DROP-1 Y2 01/20/2023 (IROFS CAL IN 2204)
C090I002 HYGROMETER CAL-DROP-1 Y2 04/11/2023 (Manual CAL IN Call) (IROFS 2204)
C090I003 THERMOCOUPLE CAL Y2 04/29/2023 (IROFS CALIB IN 2202)
C090I003 THERMOCOUPLE CAL Y2 10/29/2022 (IROFS CALIB IN 2202)
C090I004- XMITTER TTA-225A Y2 CAL IN 12/10/2022 0001 (IROFS 2202)
C090I004- XMITTER TTA-225A Y2 CAL IN 12/10/2022 0001 (IROFS 2202)
C090I007- XMITTER TTA-225B Y2 CAL IN 12/10/2022 0001 (IROFS 2202)
C090I008- XMITTER TTA-225C Y2 CAL IN 12/10/2022 0001 (IROFS 2202)
C090I009 HYGROMETER CAL-DROP-2 Y2 01/20/2023 (IROFS CAL IN 2205) 12
C080P016 ADU IX HIGH TEMP. SHUTOFFS 08/13/2022 (IROFS 12MO IN 6213)
C090P001 L2 UO2 POWDER INTERLOCKS 02/28/2023 (IROFS 6MO RE 2202, 2204, 2205, 2011)
C090P001 L2 UO2 POWDER INTERLOCKS 08/10/2022 (IROFS 6MO RE 2202, 2204, 2205, 2011)
C100P001 L2 OVERFLOW / VENTS 12MO 03/17/2022 (IROFS PF 2231)
C100P001 L2 OVERFLOW / VENTS 12MO 03/02/2023 (IROFS PF 2231)
C163P107 VALVE SHUTOFF FCV-712-4 IX 06/13/2023 (IROFS REGEN PUMPOUT 2MO OPCH 2348)
C270I007 PRESSURE XMTR PIT-00101 6 06/12/2023 (IROFS 229) MO IN C270I008 PRESSURE TRANSMIT'R PIT- 06/12/2023 (IROFS 230) 00102 6 MO IN C270I010 PRESSURE XMTR PIT-361A4 6 06/12/2023 (IROFS 243) MO IN C270I010 PRESSURE XMTR PIT-361A4 6 06/17/2022 (IROFS 243) MO IN C270I010 PRESSURE XMTR PIT-361A4 6 12/20/2022 (IROFS 243) MO IN C270P001 SURF INTERLOCK CHECK 1 YR 11/05/2021 (IROFS 243) IN C270P001 SURF INTERLOCK CHECK 1 YR 11/30/2022 (IROFS 243) IN C270P001 SURF INTERLOCK CHECK 1 YR 11/15/2020 (IROFS 243) IN C720P001 FUNCTIONAL TEST UN 1 YR RE 10/25/2022 (IROFS 736)
S065I004 Crane Scale WIT-1 05/08/2023 WO Cylinder Wash Water Tank 04/01/2022 11531802 WO Cylinder Wash TK 245 Bladder 04/22/2022 11533958 WO Cylinder Wash DIW Bladder 09/11/2022 11547078 Replace WO Cylinder Wash 245 Tank Leak 09/13/2022 11547312 13
C080P016 ADU IX HIGH TEMP. SHUTOFFS 08/13/2022 (IROFS 12MO IN 6213)
WO C065P007 UF6 Cyl Wash 03/28/2022 13547993 Hardware 6Mo OPCH WO C065P007 UF6 Cyl Wash 09/01/2022 13571926 Hardware 6Mo OPCH WO C065P007 UF6 Cyl Wash 03/01/2023 1359293 Hardware 6Mo OPCH WO C065P007 UF6 Cyl Wash 05/08/2023 13605016 Hardware 6Mo OPCH 88051 Corrective CR-2021- various various Action 2499 Documents CR-2022-1239 CR-2022-1474 CR-2022-2657 CR-2020-2392 CR-2021-0867 CR-2022-2657 Procedures E08-03-1.1 Classifying an Emergency Version 8.0 E08-03-2.1 Determining Protective Actions Version 5.0 E08-03-3.1 Plant Emergency Director Version 13.0 E08-03-3.12 Central Guard Station Officer Version 6.0 E08-03-3.8 PERT Incident Commander Version 8.0 E08-03-4.1 Incident Notification Form Version 8.0 E08-03-4.5 Plant Public Address Emergency Version 5.0 Message Format E08-03-6. Radiological Field Team Version 1.0 Procedures E08-03-6.2 Chemical Field Team Procedure Version 7.0 E08-03-6.3 Personnel Monitoring Version 4.0 E08-03-6.5 Chemical Spill Response Plan Version 8.0 E08-03-8.7 Emergency Action Guides Version 4.0 14