ML20039C622

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IE Insp Repts 50-266/81-19 & 50-301/81-21 on 811001-30. Noncompliance Noted:Failure to Establish Valve Lineup,To Change Hydrostatic Test Procedure,To Identify Isolation of Safety Injection Train & to Comply W/Radiation Work Permit
ML20039C622
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 12/10/1981
From: Guldemond W, Hague R, Konklin J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20039C610 List:
References
50-266-81-19, 50-301-81-21, NUDOCS 8112290528
Download: ML20039C622 (10)


See also: IR 05000266/1981019

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U.S. NUCLEAR REGULATORY C0rP1ISSION

REGION III

Report No. 50-266/81-19: 50-301/6.'-21

Docket No. 50-266; 50-301

License No. DPR-24; DPR-27

Licensee: Wisconsin Electric Power Campany

231 West Michigan

Milwaukee, WI 53203

Facility Name: Point Beach Nuclear Lower Plant, Units 1 and 2

Inspection At:

Point Beach site, Two Rivers, WI

Inspection Conducted: October 1-30, 1981

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Inspectors:

W.

Guldemond *

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R.

.. Hague y

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Approved By:

J.

. Konklin, Acting Chief

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ojects Section 2A

Inspection Summary

Inspection on October 1-30, 1981 (Report No. 50-266/81-19; 50-301/81-21)

Areas Inspected:

Routine resident inspection of Operational Safety Verifi-

cation, Monthly Maintenance Observation, Monthly Surveillance Observation,

Followup on Licensee Event Reports, IE Bulletin and Circular Followup,

Followup on Items of Noncompliance, Independent Inspection Effort, Contain-

ment Integrated Leak Rate Test, Receipt of New Fuel, Inspection During Long

Term Shutdown, and Refueling Activities. The inspection involved a total

of 191 inspector-hours onsite by two inspectors including 40 inspector-hours

on off-shifts.

Results: Of eleven areas inspected, no items of noncompliance were identi-

fied in eight areas. Six items of noncompliance were identified in three

areas (failure to sample boric acid tanks - Paragraph 4.a; failure to

establish a valve lineup required by a hydrostatic test procedure - Para-

graph 4.b; failure to change a hydrostatic test procedure - Paragraph 4.b;

failure to identify isolation of a safety injection train - Paragraph 2;

failure to comply with a radiation work permit - Paragraph 12; and failure

to comply with a test procedure which resulted in a reactor coolant system

pressure transient - Paragraph 4.d.).

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DETAILS

1.

Persons Contacted

  • G. A. Reed, Manager, Nuclear Ophrations
  • J. J. Zach, General Superintendent
  • T. J. Koehler, Superintendent, Operations

J. C. Reisenbuechler, Superintendent - I & C

W. J. Herrman, Superintendent, Maintenance and Construction

  • R. S. Bredvad, Health Physicist
  • R. E. Link, Superintendent - EQR
  • F. A. Zeman, Of fice Supervisor
  • G. J. Maxfield, Assistant to the Superintendent - Operaticas

The inspectors also talked with and interviewed members of the

Operations, Maintenance, Health Physics, and Instrument and Control

Sections.

  • Denotes personnel attending exit interviews.

2.

Operational Safety Verification

The inspector observed control room operations, reviewed applicable

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logs and conducted discussions with control room operators during

the month of October 1981. The inspector monitored the operability

of selected emergency systems, reviewed tagout records and verified

proper return to service of affected components. On October 22, 1981,

the inspector discovered the motor operated discharge valve for the

Unit 2 Train "A" high head safety injection pump shut. The observation

was made during a control board walkdown.

This normally open valve

does not receive an automatic open signal upon initiation of safety

inj ection. Thus, the Train "A" high head safety injection for Unit

2 was out-of-service.

The licensee immediately opened the valve and conducted an investiga-

tion.

It was determined that no one in the control room had operated

the valve during the shift. A check of the valve revealed that the

handwheel locking device was in place, which indicated that the valve

had not been operated locally. Through discussions with the Operations

Department it was determined that no tests or evolutions requiring

cycling of the Train "A" high head safety injection pump motor operated

discharge valve had been scheduled or performed.

Followup investigation by the licensee determined that the valve had

been shut when the control board switch was inadvertently bumped by

an operator changing a light bulb in the upper portion of the control

board.

It was further determined that an end-of-shift turnover check-

list which includes the positiot of the Unit 2 Train "A" high head

safety injection pump discharge valve failed to identify that the

valve was out of position.

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This is an item of noncompliance with 10 CFR 50 Appendix B, Criteria

V and XIV (50-301/81-19-01).

Tours of the Unit I containment, the auxiliary building and both turbine

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buildings were conducted to observe plant equipment conditions, includ-

ing potential fire hazards, fluid leaks, and excessive vibrations.

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Results of these tours were as follows:

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a.

Unit 1 Turbine Hall: No discrepancies were noted.

b.

Unit 2 Turbine Hall: Three valves with packing leaks were

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. identified on Octobc. 6, 1981. None had associated maintenance

requests. Two fire extinguishers had no record of inspection,

two had broken seals, and one was overcharged.

c.

Auxilia ry . Building: One fire extinguisher which was one month

overdue for monthly inspection was located in the Unit I con-

tainment facade. Numerous contamination boundaries had un-

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secured cords and hoses extending across them creating the

potential for spread of contamination within the auxiliary

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building.

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d.

Unit 1 Containment: While performing confirmatory general area

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radiation surveye ou the 66 foot level of the Unit I contain-

ment, the inspect)r discovered a frequently occupied area in

the vicinity of "B

reactor coolant pump cubicle where the

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radiation field was approximately twice the posted value (20

mrem /hr vs 10 mrem /hr). This was brought to the attention of

the licensee's health physics organization. Further investi-

gation revealed the source of the higher than expected readings

to be a tank used to store "A" reactor coolant pump internals.

This tank was properly posted with a " hot spot" tag and the

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licensee provided further posting warning of the higher than

normal radiation levels.

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All of the above items were discussed with licensee management.

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The inspector, by observation and direct interview, verified that the

physical security plan was being implemented in accordance with the

station security plan.

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The inspector observed plant housekeeping / cleanliness conditions and

verified implementation of radiation protection controls. During the

month of October 1981, the inspector walked down the accessible por-

tions of the safety injection, containment spray, emergency electrical,

auxiliary feedwater, and fire protection systems to verify operability.

These reviews and observations were conducted to verify that facility

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operations were in conformance with the requirements established under

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technical specifications, 10 CFR, and administretive procedures.

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3.

Monthly Maintenance Observation

Station maintenance activities of safety related systems and components

were observed / reviewed to verify that they were conducted in accord-

ance with approved procedures, regulatory guides and industry codes or

standards and in conformance with technical specifications.

The

following items were considered during this review:

the limiting

conditions for operation were met while components or systems were

removed from service; approvals were obtained prior to initiating-the

work; activities were accomplished using approved procedures and were

inspected as applicable; functional testing and/or calibrations were

performed prior to returning components or systems to service; quality

control records were maintained; activities were accomplished by quali-

fied personnel; parts and materials used were properly certified;

radiological controls were implemented; and fire prevention controls

were implemented.

The following maintenance activities were observed:

Removal, cleaning, testing and reinstallation of steam generator

safeties - Unit 1

Disassembly of RH MOV 700 - Unit 1

On October 27, 1981, a roll of " duct" tape war inadvertently introduced

into the Unit 1 RCS. This occurred during the disassembly of the "B"

reactor coolant pump in preparation for an inservice inspection. Health

Physics personnel were installing a herculite cover on the platform

around the pump volute. They called for more tape. A health physics

technician at the pump cubicle railing tossed a roll of tape down. The

roll of tape entered the open pump volute and rolled approximately

twelve feet down the primary loop piping. At the time of this occurr-

ence, no cover was installed over the open volute. Actual work on the

pump was interrupted for an extended period of time. At the close of

the inspection period approximately 1.5 man-rem had been received in

unsuccessful attempts at tape recovery. The tape was later recovered.

In Inspection Reports 50-266/81-17 and 50-301/81-19 the inspector

documented a concern over the licensee's lack of requirements for

installation of cleanliness covers to preclude the introduction of

foreign materials into safety related systems. The examples cited

in those reports included the electric fire pump and the 4D diesel

generator.

Because of this recent occurrence the inspector reiterated

his concern regarding c'eanliness control to licensee management.

The inspector will observe this area closely in future inspections

(50-266/81-19-01).

No items of noncompliance were identified.

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4.

Monthly Surveillance Observation

The _ inspector observed technical specifications required testing as

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noted below to ascertain whether testing was performed in accordance

with adequate procedures, test instrumentation was calibrated, limiting

conditions for operation were met, removal and restoration of the

affected components were accomplished, test results conformed with

technical specifications and procedure requirements and were reviewed

by personnel other than the individual directing the test, and any

deficiencies identified during the testing were properly reviewed and

resolved by appropriate management personnel,

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The inspectors observed all or parts of the following tests / calibrations:

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IT-210 Inservice Testing of Inaccessible Valve LCV-427

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IT-1002 Ten-Year Pressure Test of Main Steam and Main Feed Systems

IT-1003 Ten-Year Interval Pressure Test of the Auxiliary Coolant System

IT-1005 Ten-Year Pressure Test of the Safety Injection System

IT-1007 Ten-Year Pressure Test of Refueling Water Storage Tank Piping

IT-1008 Ten-Year Pressure Test of the Service Water System

IT-1010 Ten-Year Pressure Test of the Boric Acid Storage Tank Piping

Unit 1 Loop A Flow Transmitter Full Calibration

TS-31 High and Low Head Safety Valve Leakage Test

Disassembly of Unit 1, "B" reactor coolant pump in preparation

of 10 year radiographic inspection of volute welds

All. tests were carried out in accordance with approved procedures, with

the following exceptions:

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a.

Step No. 4.9 of IT-1010, Ten-Year Pressure lest of the Boric Acid

Storage Tank Piping," requires that " Chemistry verify boric acid

storage tank boric acid concentration in all three tanks." This

step was signed off on the swing shift of October 8,1981. At

10:00 a.m. on October 9, 1981, the inspector verified that the

tanks had not been sampled as required and informed the shift

supervisor who in turn requested that Chemistry immediately draw

the required samples. This is an item of noncompliance with

Technical Specification 15.6.8.1.

(50-266/81-19-02)

b.

During observation of the performance of IT-1002, " Ten-Year

Pressure Test of Main Steam and Main Feed Systems," three items

were identified.

(1) Step 2.4.2 of the procedure establishes the required test

pressure as a function of test temperature. Specifically,

the procedure requires a test pressure of 125% of design

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pressure for temperatures less than or equal to 100

F.

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For temperatures less than 200* F the procedure requires a

test pressure of 120% of design pressure. At the time of

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test performance, the test temperature _was between 110 F

and 150* F.

Based on discussions with the test engineer

and test personnel the inspector determined that the intended

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tast pressure supplied to operatioas was 125% of design

pressure. This discrepancy was pointed out by the inspector

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to operations personnel prior to exceeding 120% of design

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pressure. Operations personnel obtained technical resolution

from the test engineer. However, the procedure was not changed

in accordance with technical specification requirements. This

is an item of noncompliance with Technical Specification

15.6.8.1.

(50-266/81-19-03).

(2) Step 4.3 for the o.at I test requires that the motor operated

valves which isolate the Unit 2 steam generators from the

motor driven auxiliary feedwater pumps be shut. The valves

were observed to be open. Subsequent discussions with opera-

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tions personnel revealed that the valves had been shut on

the previous shift in preparation for the test, but had been

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reopened before shift change to establish a normal lineup for

turnover. The oncoming shift failed to reestablish the re-

quired initial conditions prior to proceeding with the test.

This is an item of noncompliance with Technical Specification

15.6.8.1.

(50-266/81-19-04)

(3) The test pressure called out was a single value. No range

was specified, making compliance virtually impossible.

Furthermore, the value called out was not identified as a

minimum or maximum value. This concern was expressed to

the licensee who agreed to specify such information in

future hydrostatic tests.

c.

During the course of the calibration of Unit 1 Loop ' flow

transmitter F-411, several adjustments were required.

It was

noted that the applicable calibration procedure was not at the

work location during these adjustments; however, all calibration

data reviewed was satisfactory.

d.

On October 10, 1981, during the performance of Major Procedure

TS-31, "High and Low Head Safety Injection Valve Leakage Test,"

on Unit 1, a Unit 1 PORV actuated. At the time of the lift the

unit 1 PORVs were aligned for low temperature overpressure

mitigation at 425 psig. The licensee's evaluation of the pressure

transient indicated that reactor coolant system pressure tempera-

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ture limits were not exceeded. The pressure transient occurred

during the performance of Step 6.8 of TS-31.

This step calls for

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switching from one train of RHR to the other and contains a pre-

caution to ensure letdown flow is maintained during the switchover.

This precaution was not complied with. This is an item of noncom-

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pliance with Technical Specification 15.6.8.1.

(50-266/81-19-05)

5.

Licensee Event Reports Followup

Through direct observations, discussions with licensee personnel, and

review of records, the following event reports were reviewed to deter-

mine that reportability requirements were fulfilled, immediate corrective

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action was accomplished, and corrective action to prevent recurrence

had been accomplished in accordance with technical specifications.

50-266/81-012/01T-0 Inadvertent Trip of Critical Control Power Breakers

50-301/81-007/03L-0 Inoperable Boric Acid Heat Tracing Circuit

50-266/81-018/03L-0 Failure to Test Safeguards Bus Undervoltage Relays

6.

IE Bulletin Followup

The inspectors reviewed the status of all outstanding IE Bulletins

and determined that none could be closed out.

7.

IE Circular Followup

For the 1E Circulars listed below, the inspector verified that the

Circular was received by licensee management, a review for applic-

ability was performed, and, if the circular was applicable to the

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facility, appropriate corrective actions were taken or were scheduled

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to be taken.

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81-12 Inadequate Periodic Test Procedure of PWR Protection System

8.

Receipt of New Fuel

The inspector verified, prior to receipt of new fuel, that technically

adequate, approved procedures were available covering the receipt,

inspection, and storage of new fuel Records of receipt inspections

and storage of new fuel of elements were reviewed for Unit 1.

No

deficiencies or itams of noncompliance were identified.

9.

Followup on Items of Noncompliance

Licensee actions in response to the items of noncompliance documented

in the inspection reports below was reviewed to ascertain whether the

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actions were completed as committed and were in conformance with

regulatory requirements.

Docket Number

Inspection Report No.

Title

50-301

81-11

Failure to report a

reactor trip pursuant

to 10 CFR 50.72

50-266

81-10

Improper Control of

50-301

81-11

transient fire hazards

10.

Independent Inspection Effort

a.

NRC Generic Letter 81-04

On February 25, 1981, the NRC issued Generic Letter 81-04 address-

ing staff concerns relative to station blackout events.

Licensees

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were directed to furnish within ninety days an assessment of

existing or planned facility procedures and training programs for

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such events.

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The licensee responded to Generic Letter 81-04 on June 9, 1981.

They adopted the position that existing plant procedures were

adequate pending review of a Westinghouse Owners Group proposal

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on emergency operating guidelines for station blackout events.

By letter dated August 21, 1981, the NRC informed the licensee

that this approach was unacceptable and requested implementation

of procedures and operator training such that they would be in

effect by about September 1981.

The licensee responded to the August 21, 1981, NRC letter on

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September 11, 1981.

In their response they committed to have

interim procedures and training completed by September 30, 1981.

On October 6, 1981, the inspectors verified that the interim

actions had been completed.

Licensee Special Order 81-03 was

reviewed and operator training confirmed through discussion with

the Operations Superintendent and the Training Supervisor.

b.

NUREG 0612

The inspectors reviewed and updated the status oi TMI Action

Plan Items. The inspector reviewed the licensee's implementation

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of NUREG 0612, " Control of Heavy Loads at Nuclear Power Plants,"

as required by December 22, 1980, and February 3,1981, letters

from D. G. Eisenhut (NRC) to Wisconsin Electric. This review

consisted of a review of PBNP 9.3, "Special Structural Limitations

on the Lifting of Heavy Loads," and discussions with managerial

and training personnel on the indoctrination of crane operators

with respect to NUREG 0612 recommendations. Two items of concern

were identified.

The first item is a discrepancy between the licensee's six month

response to the December 22, 1980, letter and PBNP 9.3.

Paragraph

4.3.2 of the former commits to Manager's Supervisory Staff approval

prior to deviation from any safe load path.

PBNP 9.3 requires such

approval for only certain load paths.

The second concern relates to the use of such portable lifting

equipment as chain falls. The licensee has not addressed control

of such equipment in either his submittals in response to NUREG 0612 or in PBNP 9.3.

That the use of such equipment should be of

concern was illustrated by two observations of a questionable

lifting practice during the inspection period.

In both cases

chain falls to be used in lifting equipment were attached to

overhead piping.

In neither case was an analysis performed to

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demonstrate that the lifting configuration was adequate to

support the intended load.

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These concerns were expressed to licensee management, who have

taken them under consideration.

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11.

Containment Integrated Leak Rate Test

The resident inspectors, in conjunction with Region III inspectors,

monitored activities associated with the Unit I containment integrated

leak rate test.

Included in the review were review of the procedure

for technical adequacy, determination that the procedure was avail-

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able and being used by test personnel, verification that the special

test equipment required by the procedure was calibrated and in service,

verification of initial conditions and system lineups, monitoring of

key parameters during the test, and verification that post-test blowdown

was within technical specification radioactivity release limits. The

resident inspectors also conducted an independent post-test containment

inspection for equipment degradation.

No items of noncompliance were identified. However, the inspectors

did determine that ORT #9, " Preparation for . Integrated Leak Rate Test,"

contained numerous out-of-date valve lineups. The licensee indepen-

dently made the same determination and processed the necessary pro-

cedural changes. The cause of this problem was failure to update the

ORT as system modifications were made. This situation was discussed

with the licensee, who is considering various alternative corrective

actions. Effort is currently being expended to update procedures and

valve lineups for the Unit 2 containment integrated leak rate test

scheduled for April 1982.

12.

Inspection During Long Term Shutdown

The inspector monitored Unit 1 shutdown operations, reviewed

applicable logs, and conducted discussions with operators during

October 1981.

Based on these reviews it was determined that two

significant items were not recorded in the station log. These were

the introduction of foreign material into the reactor coolant system

described in Paragraph 3, and the system pressure transient described

in Paragraph 4.

Tours of Unit I areas were conducted to verify tagout procedure

implementation and to observe plant equipment conditions including

potential fire hazards, fluid leaks, and excessive vibrations. Also

monitored were housekeeping / cleanliness conditions, implementation

of radiation protection controls, and implementation of the station

security plan.

The inspector performed a spot check of compliance with a Radiation

Work Permit (RWP) issued to support maintenance activities on the

"B" reactor coolant pump on October 15.

The RWP called for personnel

protective clothing, including cotton gloves. The inspector observed

one individual entering the reactor coolant pump cavity and performing

work associated with the RWP without gloves of any kind. This was

pointed out to a Health Physics Technician in the area, who attempted

to correct the situation. The individual in the cavity initially

resisted donning gloves and Health Physics supervision had to get

involved. This is an item of noncompliance with Technical Specifi-

cation 15.6.8.1.

(50-266/81-19-06)

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13.

Refueling Activities

Prior to fuel handling the inspector verified that all surveillance

testing required by technical specifications and licensee procedures

for fuel handling had been completed. The inspectors witnessed several

shifts of fuel handling during the core off-load. Staffing during

off-load was in accordance with technical specifications. Good house-

keeping practices were observed in the fuel handling areas and contain-

ment integrity was maintained as required by technical specifications.

During inspection of the off-loaded fuel the licensee observed a tear

in the bottom of the No. 2 grid strap on one of the assemblies. This

assembly is scheduled to be returned to the core and the licensee is

continuing their evaluation. The inspectors will followup on this

finding and its resolution.

(50-266/81-19-07)

14.

Exit Interview

The inspectors met with licensee representatives (denoted in Paragraph

1) throughout the month and at the conclusion of the inspection period

and summarized the scope and findings of the inspection activities.

The licensee acknowledged the findings.

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