ML22251A389
| ML22251A389 | |
| Person / Time | |
|---|---|
| Site: | 99901013 |
| Issue date: | 09/09/2022 |
| From: | Kerri Kavanagh NRC/NRR/DRO/IQVB |
| To: | Riley L Pooled Equipment Inventory Co |
| Aaron Armstrong, 301-415-8396 | |
| References | |
| "EPID I-2022-201-0120 IR 2022201 | |
| Download: ML22251A389 (16) | |
Text
Ms. Lynn Riley PIM QA Manager Pooled Equip Inventory Co (PEICo) 3535 Colonnade Parkway Birmingham, AL 35243
SUBJECT:
NUCLEAR REGULATORY COMMISSION VENDOR INSPECTION REPORT OF POOLED EQUIPMENT INVENTORY CO. NO. 99901013/2022-201
Dear Ms. Riley:
On July 25 through July 28, 2022, the U.S. Nuclear Regulatory Commission (NRC) conducted an inspection at Pooled Equipment Inventory Company (PEICo) Strategic Alliance for FLEX Emergency Response (SAFER) facility in Memphis, TN. The purpose of the inspection was to evaluate the Pooled Inventory Management (PIM) which is a contracted agent of PEICo (hereafter referred to as PEICo/PIM), for the support activities of the SAFER program.
PEICo/PIMs SAFER activities support the nuclear industry by warehousing, maintaining, testing, and deploying Phase 3 SAFER FLEX equipment. Phase 3 SAFER FLEX equipment enables mitigation strategies first identified in NRC Order EA-12-049, Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events. PEICo/PIMs Phase 3 SAFER FLEX program is based on guidance in NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Section 12, Off-Site Resources, to meet the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.155, Mitigation of beyond-design basis events. The enclosed report presents the results of this inspection. This NRC inspection report does not constitute NRC endorsement of your overall quality assurance or Part 21 programs.
Based on the results of this inspection, the NRC inspection team found the implementation of your QA program met the applicable technical and regulatory requirements imposed on you by your customers or NRC licensees. No findings of significance were identified.
September 9, 2022
L. Riley 2
In accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRCs Rules of Practice, the NRC will make available electronically for public inspection a copy of this letter and its enclosure through the NRCs Public Document Room or from the NRCs Agencywide Documents Access and Management System, which is accessible at http://www.nrc.gov/reading-rm/adams.html.
Sincerely, Kerri A. Kavanagh, Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation Docket No.:
99901013 EPID No.:
I-2022-201-0120
Enclosures:
- 1. Inspection Report No. 99901013/2022-201 and Attachment Signed by Kavanagh, Kerri on 09/09/22
ML22251A389 NRR-106 OFFICE NRR/DRO/IQVB NRR/DRO/IQVB NRR/DRO/IQVB NAME AArmstrong OAyegbusi KKavanagh DATE 09/09/2022 09/09/2022 09/09/2022
Enclosure U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF REACTOR OVERSIGHT VENDOR INSPECTION REPORT Docket No.:
99901013 Report No.:
99901013/2022-201 Vendor:
Pooled Equip Inventory Co (PEICo)
Barnhart Crane & Rigging 1701 Dunn Ave.
Memphis, TN 38106 Vendor
Contact:
Ms. Lynn Riley PIM QA Manager Email: clriley@southernco.com Office: (205) 992-5421 Nuclear Industry Activity:
Pooled Inventory Management (PIM), as agent for PEICo, and under contract to support the Strategic Alliance for FLEX Emergency Response (SAFER) program, is responsible for the storage, maintenance, and testing of the additional off-site equipment, when deployed; and provide the capability and redundancy for power plants until power, water, and coolant injection systems are restored or commissioned (Phase 3). Phase 3 SAFER FLEX equipment is used by NRC licensees to mitigate the consequences of beyond-design-basis external events.
Inspection Dates:
July 25 - July 28, 2022 Inspectors:
Aaron Armstrong NRR/DRO/IQVB Team Leader Odunayo Ayegbusi NRR/DRO/IQVB Approved:
Kerri A. Kavanagh, Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
2 EXECUTIVE
SUMMARY
PEICO/PIM SAFER Program 99901013/2022-201 The U.S. Nuclear Regulatory Commission (NRC) conducted a vendor inspection of the Pooled Equipment Inventory Company (PEICo) Strategic Alliance for FLEX Emergency Response (SAFER) facility in Memphis, TN. The purpose of the inspection was to evaluate the Pooled Inventory Management (PIM) which is a contracted agent of PEICo (hereafter referred to as PEICo/PIM), for the support activities of the SAFER program. PEICo/PIMs SAFER activities support the nuclear industry by warehousing, maintaining, testing, and deploying of Phase 3 SAFER FLEX. Phase 3 SAFER FLEX equipment enables mitigation strategies first identified in NRC Order EA-12-049, Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events. PEICo/PIMs Phase 3 SAFER FLEX program is based on guidance in NEI 12-06, Diverse and Flexible Coping Strategies (FLEX)
Implementation Guide, Section 12, Off-Site Resources, to meet the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.155, Mitigation of Beyond-Design Basis Events. The enclosed report presents the results of this inspection. PEICo/PIM has established an Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, and 10 CFR Part 21 Reporting of Defects and Noncompliance, program. However, the NRC inspection team determined that not all activities are required to be done in accordance with these regulations. This NRC inspection report does not constitute NRC endorsement of your overall quality assurance or Part 21 programs.
This inspection of PEICo/PIM focused on the SAFER program as it applies to supporting the beyond design mitigation efforts including procurement, maintenance, testing, and storage of the additional off-site equipment. When Phase 3 SAFER FLEX is deployed, it provides the capability and redundancy for power plants until power, water, and coolant injection systems are restored. Phase 3 SAFER FLEX equipment is used by NRC licensees to mitigate the consequences of beyond-design-basis external events. The Memphis, TN facility shares the same overall programmatic processes (i.e. procedures, qualification, procurement, etc.) as the Phoenix, AZ facility. The NRCs inspection of PEICo/PIMs SAFER program is required, on an alternating triennial basis, at both the Memphis and Phoenix locations. Specific activities observed by the NRC inspection team included:
The NRC inspection team observed quarterly maintenance activities being performed using Work Instruction (WI)-2-10-TGM for a 4160 volts alternating current (VAC)
Turbine Generator unit.
These regulations served as the bases for the NRC inspection:
10 CFR 50.155 10 CFR 50, Appendix B 10 CFR Part 21
3 During the course of this inspection, the NRC inspection team implemented portions of Inspection Procedure (IP) 36100, Inspection of 10 CFR Part 21 and Programs for Reporting Defects and Noncompliance, dated May 16, 2019; IP 43002, Routine Inspections of Nuclear Vendors, dated January 27, 2017; and IP 43006, Inspection of the implementation of Mitigation Strategies Order Regulating the Use of National SAFER Response Centers. The information below summarizes the results of this inspection.
SAFER Program The NRC inspection team reviewed PEICo/PIMs policies and implementing procedures that govern the overall implementation of the SAFER program including storage, maintenance, procurement, testing, and deploying activities. Based on the limited sample of documents reviewed, the NRC inspection team also determined that PEICo/PIM is implementing its policies and procedures associated with the SAFER program. No findings of significance were identified.
Procurement Document Controls and Internal Audits The NRC inspection team concluded that PEICo/PIM is implementing the necessary procurement controls in accordance with NEI 12-06. Based on the limited sample of documents reviewed, the NRC inspection team also determined that PEICo/PIM is implementing its policies and procedures associated with the procurement activities. No findings of significance were identified.
Measuring & Test Equipment (M&TE) Control The NRC inspection team concluded that PEICo/PIM is adequately implementing its M&TE program in accordance with NEI 12-06. Based on the limited sample of documents reviewed, the NRC inspection team also determined that PEICo/PIM is implementing its policies and procedures associated with the maintenance activities. No findings of significance were identified.
Test and Maintenance The NRC inspection team concluded that PEICo/PIM is adequately implementing its test and maintenance program in accordance with NEI 12-06. Based on the limited sample of documents reviewed, the NRC inspection team also determined that PEICo/PIM is implementing its policies and procedures associated with test and maintenance activities. No findings of significance were identified.
Handling, Storage, and Deployment The NRC inspection team concluded that PEICo/PIM is implementing its handling, storage, and deployment activities in accordance with NEI 12-06. Based on the limited sample of documents reviewed, the NRC inspection team also determined that PEICo/PIM is implementing its policies and procedures associated with the handling of SAFER equipment. No findings of significance were identified.
4 Corrective Actions The NRC inspection team concluded that PEICo/PIM is implementing its corrective action program in accordance with NEI 12-06. Based on the limited sample of documents reviewed, the NRC inspection team also determined that PEICo/PIM is implementing its policies and procedures associated with the corrective action program. No findings of significance were identified.
5 REPORT DETAILS 1.
SAFER Program a.
Inspection Scope The U.S. Nuclear Regulatory Commission (NRC) inspection team reviewed Pooled Equipment Inventory Companys (PEICos)/Pooled Inventory Managements (PIMs) policies and implementing procedures that govern the overall implementation of the Strategic Alliance for FLEX Emergency Response (SAFER) program including storage, maintenance, procurement, testing, and deploying activities. The NRC inspection team evaluated PEICo/PIMs SAFER program processes which include the development of procedures governing all activities including determination of procurement technical specifications, vendor selection, receipt inspection, periodic maintenance, adequate testing, adequate storage, and development of training for on-site staff and staff activated during an emergency. The NRC inspection team reviewed the policies and a sample of implementing procedures for PEICo/PIMs Phase 3 FLEX equipment stored at the Memphis, TN National SAFER Response Centers (NSRC) facility to verify that the control processes were effectively implemented throughout the various stages from procurement, testing, and storage. PEICo/PIM has established an Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to Title 10 of the Code of Federal Regulations(10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, and 10 CFR Part 21, Reporting of Defects and Noncompliance, program. However, the NRC inspection team determined that not all activities are required to be done in accordance with these regulations. The attachment to this inspection report lists the individuals interviewed and documents reviewed by the NRC inspection team.
b.
Observations and Findings No findings of significance were identified.
c.
Conclusions The NRC inspection team concluded that PEICo/PIM is adequately implementing its SAFER program controls in accordance with its policies and procedures. Based on the limited sample of documents reviewed, the NRC inspection team also determined that PEICo/PIM is implementing its policies and procedures consistent with the requirements of 10 CFR 50.155, Mitigation of Beyond-Design Basis Events.
2.
Procurement Document Controls and Internal Audits a.
Inspection Scope The NRC inspection team reviewed PEICos/PIMs policies and implementing procedures that govern the implementation of its procurement document controls and internal audits. Specifically, the NRC inspection team reviewed PEICos/PIMs purchase orders (POs), receipt inspection reports (RIRs) and verified that equipment requirements from the manufacturer were incorporated into work instructions.
6 In general, the current POs being placed are for maintenance services, replacement parts, and deployment services. The NRC inspection team verified that contracts with trucking and air providers are in place, valid and updated to ensure assumptions (i.e. no single external event will preclude capability to supply needed resources to licensees) for deployment of FLEX equipment remain valid. The NRC inspection team reviewed the PEICos/PIMs internal audit from 2021performed by an independent contractor. The NRC inspection team reviewed the associated PO and verified the independence of the contractor that performed the internal audit.
The NRC inspection team also discussed the procurement document control and internal audit programs with PEICos/PIMs management and technical staff. The attachment to this inspection report lists the documents reviewed and the staff interviewed by the NRC inspection team.
b.
Observations and Findings No findings of significance were identified.
c.
Conclusion The NRC inspection team concluded that PEICo/PIM is adequately implementing its procurement document control and internal audit programs in accordance with its policies and procedures. Based on the limited sample of documents reviewed, the NRC inspection team also determined that PEICo/PIM is implementing its policies and procedures consistent with the requirements of 10 CFR 50.155.
3.
Measuring & Test Equipment Control (M&TE) a.
Inspection scope The NRC inspection team reviewed PEICos/PIMs policies and implementing procedures that govern the M&TE program to verify compliance with the requirements of 10 CFR 50.155. The NRC inspection team observed that M&TE was calibrated, labeled, tagged, handled, stored, or otherwise controlled to indicate the calibration status and its traceability to nationally recognized standards. The NRC inspection team also confirmed that when M&TE is found to be out of calibration, PEICo/PIM initiates a nonconformance report and performs an evaluation to determine the extent of condition.
The NRC inspection team also discussed the M&TE program with PEICos/PIMs management and technical staff. The attachment to this inspection report lists the documents reviewed and the staff interviewed by the NRC inspection team.
b.
Observations and Findings No findings of significance were identified.
7 c.
Conclusion The NRC inspection team concluded that PEICo/PIM is adequately implementing its M&TE program in accordance with its policies and procedures. Based on the limited sample of documents reviewed, the NRC inspection team also determined that PEICo/PIM is implementing its policies and procedures consistent with the requirements of 10 CFR 50.155.
4.
Test and Maintenance d.
Inspection scope The NRC inspection team reviewed procedures for tests, preventive maintenance, test objectives, test requirements, and acceptance criteria contained in the applicable technical documents. Specifically, the NRC inspection team reviewed PEICos/PIMs procedures for performing quarterly maintenance on the 4160 volts alternating current (VAC) Turbine Generator using a PEICo/PIM 4160 VAC load distribution center. The NRC inspection team reviewed Work Instruction (WI)-2-10 for 4160 VAC for the turbine generators quarterly maintenance, WI-GP-12 for the replacement of the turbine generators starting nozzle, and WI-GP- 09 for battery checks for Phase 3 FLEX equipment.
The NRC inspection team observed quarterly maintenance of a PEICo Turbine Marine manufactured, 4160 VAC Turbine Generators (TGM07). PEICo contracts Barnhart Crane and Rigging to handle equipment, house, and perform maintenance at the Memphis NSRC facility. The NRC inspection team observed Barnhart personnel performing maintenance per WI-2-10, Version 11, dated July 26, 2022, including their safety pre-job brief to verify they followed warnings, cautions, and notes per the work instruction procedures. The NRC inspection team verified Barnhart recorded and verified values were within maintenance thresholds. The NRC inspection team verified that the 4160 VAC turbine generator load center settings were appropriate to ensure compliance with work instructions. The NRC inspection team interviewed PEICo/Barnhart personnel and reviewed training records to ensure the personnel were qualified.
The NRC inspection team also discussed the testing and maintenance program with PEICos/PIMs management and technical staff. The attachment to this inspection report lists the documents reviewed and the staff interviewed by the NRC inspection team.
e.
Observations and Findings No findings of significance were identified.
f.
Conclusion The NRC inspection team concluded that PEICo/PIM is adequately implementing its testing and maintenance program in accordance with its policies and procedures. Based on the limited sample of documents reviewed, the NRC inspection team also determined that PEICo/PIM is implementing its policies and procedures consistent with the requirements of 10 CFR 50.155.
8 5.
Handling, Storage, and Deployment a.
Inspection Scope The NRC inspection team reviewed PEICos/PIMs handling, storage, and deploying policies and procedures to verify conformance with the requirements of 10 CFR 50.155. The NRC inspection team observed how the Phase 3 FLEX equipment is stored, cataloged, and tracked for easy deployment to the correct NRC licensee that requests the equipment. The NRC inspection team discussed the conduct of the warehouse operations for all the handling activities with PEICos/PIM's management.
The NRC inspection team performed walk downs of the different storage sections to verify the Phase 3 FLEX equipment described in the emergency deployment procedures and the bill of ladings matched the different transportation pallets. The NRC inspection team verified that the procedures provided adequate guidance for the easy identification of equipment location and for licensee-specific equipment, it properly identified the necessary Phase 3 FLEX equipment.
The NRC inspection team verified that the storage facility would provide the necessary protection of the equipment and meet the availability requirements in accordance with the mitigation strategies requirements in 10 CFR 50.155. All samples of equipment verified for storage condition were adequately preserved and maintained. The NRC inspection team verified that all the documentation at the Memphis facility for deployment of equipment when called upon during an emergency was up to date and reflected the current conditions of the warehouse.
The NRC inspection team also discussed the handling, storage, and deployment program with PEICos/PIMs management and technical staff. The attachment to this inspection report lists the documents reviewed and the staff interviewed by the NRC inspection team.
b.
Observations and Findings No findings of significance were identified.
c.
Conclusions The NRC inspection team concluded that PEICo/PIM is adequately implementing its handling, storage, and deployment programs in accordance with its policies and procedures. Based on the limited sample of documents reviewed, the NRC inspection team also determined that PEICo/PIM is implementing its policies and procedures consistent with the requirements of 10 CFR 50.155.
9 6.
Corrective Action Program a.
Inspection Scope The NRC inspection team reviewed PEICo/PIMs policies and implementing procedures for the Corrective Action Program (CAP) and Nonconformance Report (NCR) Program to ensure prompt identification, correction, and verification of effectiveness in accordance with the requirements of 10 CFR 50.155. The NRC inspection team reviewed a sample of PEICos/PIMs CARs and NCRs and verified that procedures are established and implemented for correcting conditions affecting Phase 3 FLEX equipment. The sample of CARs and NCRs provided for documenting and describing the nonconforming condition, the cause and corrective action taken to prevent recurrence of the nonconforming condition. PEICos/PIMs policies and implementing procedures adequately assess and document program deficiencies, receipt inspection rejections, equipment malfunction, and maintenance test failures in its corrective action program. The NRC inspection team also reviewed corrective actions resulting of the Phase 2 Susquehanna Turbine Generator maintenance testing failure. The attachment to this inspection report lists the individuals interviewed and documents reviewed by the NRC inspection team.
b.
Observations and Findings No findings of significance were identified.
c.
Conclusions The NRC inspection team concluded that PEICo/PIM is adequately implementing its corrective action and nonconformance programs in accordance with its policies and procedures. Based on the limited sample of documents reviewed, the NRC inspection team also determined that PEICo/PIM is implementing its policies and procedures consistent with the requirements of 10 CFR 50.155.
- 7. Entrance and Exit Meetings On July 25, 2022, the NRC inspection team discussed the scope of the inspection with Ms.
Lynn Riley, PEICo/PIMs PIM QA Manager, and other members of PEICos/PIMs management and technical staff. On July 28, 2022, the NRC inspection team presented the inspection results and observations during an exit meeting with Ms. Lynn Riley, other members of PEICo/PIM s management and technical staff. The attachment to this report lists the attendees of the entrance and exit meetings, as well as those individuals whom the NRC inspection team interviewed.
ATTACHMENT 1.
ENTRANCE/EXIT MEETING ATTENDEES Name Title Affiliation Entrance Exit Interviewed David Crawley Senior PMO Manager PEICo/PIM (SNC)
X X
X Lynn Riley PIM QA Manager PEICo/PIM (SNC)
X X
X Mark Boggs Facilities & Maintenance Manager PEICo/PIM (SNC)
X X
X Lesa Hill PIM Program Manager PEICo/PIM (SNC)
X X
Phil Amway SAFER Chairman PEICo/PIM Constellation
)
X X
Scott Stewart SAFER Project Manager PEICo/PIM (SNC)
X X
X Greg Roberson Phoenix NSRC Supervisor PEICo/PIM (SNC)
X X
Carl Sower Safer Framatome X
X Drew Weiser SAFER Program Manager Framatome X
X Diane Coffin PIM Engineering Sup PEICo/PIM (SNC)
X X
David Handly Accounting Manager PEICo/PIM (SNC)
X X
Ashley Merritt Accountant PEICo/PIM (SNC)
X X
Biko Freeman Engineer PEICo/PIM (SNC)
X X
Greg Clark Engineer PEICo/PIM (SNC)
X X
Greg Green Warehouse Sup Memphis PEICo/PIM (SNC)
X X
Janet Fondren Project Support Analyst PEICo/PIM (SNC)
X X
John Allen Roberts Contract manager PEICo/PIM (SNC)
X X
Kathy Padilla Records Specialist PEICo/PIM (SNC)
X X
Kelly Meglich Accountant PEICo/PIM (SNC)
X X
ii Keven Shea Sourcing Specialist PEICo/PIM (SNC)
X X
Kory Pimentel Materials Analyst PEICo/PIM (SNC)
X X
Rebecca Retherford Engineer PEICo/PIM (SNC)
X X
Lisa Fraser Contact Manager PEICo/PIM (SNC)
X John Mclean Engineer PEICo/PIM (SNC)
X X
Aaron Armstrong Inspection TL NRC X
X Odunayo Ayegbusi Inspection Team Member NRC X
Kerri Kavanagh Branch Chief NRC X
Chris Miller Director, DRO NRC X
2.
INSPECTION PROCEDURES USED
Inspection Procedure (IP) 36100, Inspection of 10 CFR Part 21 and Programs for Reporting Defects and Noncompliance, dated May 16, 2019
Inspection Procedure 43002, Routine Inspections of Nuclear Vendors, dated January 27, 2017
IP 43006, Inspection of Implementation of Mitigation Strategies Order Regarding the Use of National Safer Response Centers dated June 16, 2022 3.
DOCUMENTS REVIEWED Policies and Procedures PEICo Quality Assurance Manual Version", Revision 10, dated July 14, 2022 PPM 2-1, Training of Personnel, dated October 7, 2021 PPM 2-3, Training of Personnel, dated September 27, 2021 PPM 4-8, Preparation and Revision of Test Procedures, dated April 12, 2016 PPM 7-1, Quality Assurance Audits, dated September 29, 2020 PPM 7-9, Auditor and Lead Auditor Qualification, dated May 23, 2017 AP-11, Identification of Substandard and/or Fraudulent Items, October 11, 2017 PPM 2-4, National SAFER Response Center Activities, dated May 18, 2022 AP-2, Material Handling, dated January 14, 2014 AP-14, Equipment/Material Receiving, dated November 18, 2021 AP-16, Controls for Measuring and Test Equipment, dated March 1, 2022
iii PPM 7-7, Corrective Action Program, dated December 9, 2021 AP-15, Equipment/Material Storage and Inventory Control, dated November 18, 2021 PPM 8-2, Reporting of Defects and Noncompliance, dated February 26, 2018 PPM 7-11, Control of Nonconforming Items, dated December 9, 2021 Work Order C103723, dated March 18, 2022 Work Order C103518, dated November30, 2021 Work Order C103358, dated September 30, 2021 Work Order P124482, dated June 9, 2022 Procurement Documents Purchas order (PO) 202140-W0-0193, Full Scope Audit Services, Dated December 5, 2021 PO 201881-0013, Pressure gage Calibrations, dated January 31, 2020 PO 201881-0013, Calibrations blanket, dated December 11, 2018 PO 201881, Calibration Blanket, dated December 11, 2018 Measuring and Test Equipment (M&TE)
Wok Order (WO) P118521, High Pressure Injection Pump, dated December 28, 2020 WO C103203, Vacuum Gage and Flow Meter, dated June 18, 2020 WO P118746, Suction Lift Boost Pump, dated December 28, 2020 WO C102610, Pressure gages, dated September 2, 2020 WO C103056 Gauge Pressure 0 - 1000 PSI Graduations 2 PSI, dated May 12, 2021 Contracts for Trucking and Air providers Assignment from FedEx Custom Critical to Federal Express Corporation, dated June 4, 2021 FedEx Custom Critical Transportation Services Agreement for Ground and Fixed Wing Air Transportation and amendments, dated September 5, 2014 Doc ID: RE002339168, Call When Needed Helicopter Transportation Services Agreement, dated August 5. 2014 Doc ID: RE002162600, Call When Needed Helicopter Transportation Services Agreement, dated April 13, 2014 Doc ID: RE002339127, Call When Needed Helicopter Transportation Services Agreement, dated August 4, 2014
iv Doc ID: RE002139436, Call When Needed Helicopter Transportation Services Agreement, October 13, 2014 Doc ID: RE002139436, Call When Needed Helicopter Transportation Services Agreement, dated January 16, 2015 Corrective Action/Nonconformance Reports CAR No. 21-17, dated July 29, 2021 CAR No. 22-20, dated July 27, 2022 CAR No. 21-11, dated May 24, 2021 CAR No. 20-25, dated December 22, 2020 NCR No. 821, dated April 5, 2022 NCR No. 756, dated December 7, 2020 NCR No. 820, dated March 30, 2022 Training Records Barnhart Technician, dated April 5, 2021 Barnhart Technician, dated April 5, 2021 Barnhart Technician, dated April 5, 2021 Record of Lead Auditor Qualifications, Mervak, dated July 21, 2021 Record of Lead Auditor Qualifications, Pollock, dated July 21, 2021 Record of Lead Auditor Qualifications, Crawley, dated February 23, 2022 Record of Lead Auditor Qualifications, McLean, dated October 29, 2021 Audit 2021 Annual Full Scope Audit for July 26-Aug 9, 2021, Dated August 27, 2021