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j NUCLEAR REGULATORY COMMIS$10N
/j REoloN I 474 ALLENoALE ROAo
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Dear The NRC Region I has completed its followup of the concerns that you brought to our our attention by way of rnemoranda dated October 7, September 29, and October 9,1990, alleging (1) procedural non compliance with SP EE 076, (2) a technical specification violation during instrument and controls troubleshooting, (3) an improper tagout during maintenance, and (4) a failure to comply with procedural requirements during fuel movement.
With regard to issue (1), we have previously documented our review of this item in an inspection repon 50-336/8913 and in a letter to you dated June 13,1990 (attached). We consider this matter both unsubstantiated and closed. The reason this issue is unsubstantiated -
is that you have not provided documented evidence that compliance with explicit provisions I of SP-EE-076 is recuired in the conduct of activities at h!illstone Unit 2.
i With regard to issue (2), you alleged that no diesel generator power source was available during the maintenance. We documented our review of this item in inspection report 50 336/
90-22, section 5.1.2 (attached). As documented in our report, emergency power was ,
available from a number of sources including manual start of the affected diesel generator.
Having only one diesel available by manual stan is a condition allowed during refueling at blillstone Unit 2. Your allegation is therefore unsubstantiated. We consider this matter closed.
With regard to issue (3), you alleged that maintenance was performed on the "A" steam generator feedwater regulating valve with an improper tagout. We reviewed this allegation in inspletion report 50-336/90-22, section 5.1.1 (attached). We found that all required documentation and authonzations were used in the electrical isolation. Your allegation was therefore unsubstantiated and we consider this matter closed.
Information in this record was deleted in accordance will} th! f4egdom of information Act, expligns In - IC F01A 7 "ILD t
9212220049 920608 PDR FOIA f CUILD91-162 PDR ID
With regard to issue (4), you alleged that a direct violation of procedures occurred during l fuel movement. We reviewed this allegation in inspection report 50 336/90-22, section 9.8 l (attached), and found that the procedure was adhered to during the operations however some additional procedural detail may have prevented the problem.. Your allegation was therefore t unsubstantiated and we consider this matter closed.
Should you have any additional questions or if I can be of funhet assistance in these matters, please call me collect at (215) 337 5225.
Si icerely,p
&/ s Edward Wenzinger, hie /
Reactor Projects Bran 4U Attachments: As stated bec:
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19
- The activities listed below warranted additional inspector followup.
5.1.1 Preventive Maintenance on #2 Steam Generator Feedwater Reculatinc Valve Unit 2 s
The inspector reviewed the adequacy of the electrical isolation of the #2 feedwater regulating valve and the personnel safety precautions associated with the preventive maintenance activity, Authorized work order (AWO) M2 90 6019, was the controlling document for the preventive maintenance on the #2 steam generator feedwater regulating valve (2 FW 51B). In preparation for the mechanical maintenance, a station electrician was required to deenergize and disable the motor operator thus allowing the mechanic's unobstructed access to the valve.
Electrical tagout 21829 90 was authorized removing operating power from the motor operator. The feedwater regulating valve motor operator has control and feedback power leads, eight of which are lifted from a terminal board by the electrician to establish complete electrical isolation. The lifting of leads is controlled by station procedure ACP.
QA 2.06C " Station Bypass Jumper Control for Troubleshooting, Redlining, and Calibration", which allows form SF 235 to be used as a record that leads were lifted and landed as part of the maintenance activity. The AWO contained the completed SF 235 with verifications of both lifung and landing the leads. The inspector concluded that proper documentation and authorizations were used in the electrical isolation. The inspector noted that the AWO did not identify (as a caution statement) that electrical isolation would require the lifting of .
leads in addition to the tagout. Although the maintenance is performed yearly on two FWRVs and the electrical isolation requirements are well known by electncal personnel and supervision, the caution statement is considered a Sood safety enhancement and was discussed by the ,
inspector with maintenance planning inanagement. Work group electricians in cases such as these could ensure that the caution statement is added by informing the maintenance planning group.
$.12 Troubleshootinc of Facility 2 Encineered Safecuards Actuation Cabinet Unit 2 The inspector reviewed the prerequisites and plant conditions associated l
with authorized work order (AWO) M2 90-10941 to troubleshoot the-facility 2 engineered safeguards actuation circuit, while the plant was in L Mode 6 (refueling). To prevent inadvertent engineered safety feature actuations during troubleshooting, the 24 volt supply fuses were removed prior to work. This initial condition disabled the autostart p
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4 20 feature of the emergency diesel generator on toss of normal power (LNP) and would require, as one option, that operators manually start the diesel to facilitate restoration of power. De inspector verified through discussions with the work group, operations department '
supervision, operator training management, instrument and controls management, and plant director, that the loss of diesel autostart capability on LNP was known and understood by the work group, '
operators, and management, that the operators were briefed and trained on actions required in event of LNP, and that proper coordination between the work group, operations, and management was maintained during the troubleshooting. The technical specifications, final safety analysis report, and codes and industry standards were also reviewed and no conflicts were identified. The inspector concluded that proper actions were taken by all licensee groups involved and that the trouble-shooting was conducted in a professional and efficient manner.
5.1.3 Non conservante Main Steam Line Radiation Monitor Setnoint Unit 1 On October 22,1990, at 3:05 pm, with the plant at 100% of rated power, the licensee determined that the four main steam line (MSL) radia: ion monitor high high radiation trip serpoints were non-conservative. The trip serpoints had been adjusted upward at 10:57 am in accordance with procedure SP406C, Main Steam Line Radiation Drawer Calibration, revision 15, change 1, in preparation for transfer of demineralizer resin scheduled for October 23. The licensee declared the -
monitors inoperable and 'mmediately commenced resetting the instrument setpoints to the proper value. By 3:25 pm adjustments were complete and the monitors were declared operable. At 3:35 pm the licensee simultaneously declared and terminated a Notification of an Unusual Esent pursuant to its emergency plan implementing procedures +
and, following timely noti 6 cation to state and local agencies, noti 6ed the NRC Operations Center of the event as required by 10 CFR 50.72(b)(1)(i)(A), initiation of any nuclear plant shutdown required by a plant's technical specifications.
Tre purpose of the MSL radiation instruments is to minimize the release of radioactive material to the environment by continuously monitonng radiation levels in the steam lines. This provides prompt indication of release of fission product gases indicative of gross fuel cladding failure. Radiation levels of three times normal background -
cause an alarm to annunciate in the control room, An automatic reactor trip and closure of main steam isolation valves occurs at radiation levels of seven times normal background. The trip setpoint is high enough to avoid spurious trip signals while low enough to detect and isolate abnormal amounts of radioactive material in the MSLs.
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.o 75 traceability between the located dust coser at the Fh1E area and the missing dust cover could be ascertained. The licensee dimensional review of reactor internals supplemented by ABB Combustion Engineering, was extensive and considered all possible locations in the event the dust cover lodged within the '
reactor vessel upper guide structure.
The review of localized flow conditions and flow conditions necessary to move .
the dust cap within the reactor coolant system were appropriately included in the evaluation. The licensee engineering determination that the dust cover in the reactor coolant system would not adversely affect components was adequate based on geometric configuration, and weight of the dust cap. Licensee corrective actions to improve procedural accountability of ICI dust caps will be reviewed in future inspections.
9.S Control Element Assembly Bent During Refueline Oxtations Esent Descriotion I
On October 5,1990, during in core refueling operations, the licensee identified that control element assembly (CEA) 131 had been damaged. The deformation to CEA-131 resulted when the fuel handling spreader interfered with the CEA o spider. The spreader interference resulted in raising the adjacent CEA (CEA-131). Further, the bending of the CEA fingers resulted during lateral movement of the refuel trolley and bridge. The controlling procedure was OP.
2303 Refueling hiachine Operation From Core to Upender, section 5.7. Step 5.7.18 requires verification of the spreader "up" limit switch indication, and a visual check that no adjacent CEAs have been lifted by the spreader.
Licensee Corrective Actions The licensee documented the event in plant incident report (PIR) 90 Il2, and evaluated the condition of fuel assembly hi 15 containing CEA 131 in nonconformance report (NCR) 290-264. Authorized work o? der (AWO) h12-90-1186; documented inspection results of fuel assembly 615. The inspection of the fuel assembly was performed using fuel vendor procedure ANF 1362(P).
The immediate licensee corrective actions were to reposition the refuel machine and disengaged the spreader from the CEA 131 spider. CEA-131 and fi'el assembly hi 15 were removed from the reactor vessel and stored into the s,nent fuel pal for examination. Video examination ;n the spent fuel pool indicated all five CEA fingers were ber.t at 21 Mches (approximately 13% of active finger length) from the top of'.he CEA spider.
76 On October 8, the licensee performed a free path / drag test of fuel assembly M-15 using CEA-6. The CEA was fully inserted and then fully withdrawn while observing the load cell. No underloads upon CEA insertion and no overloads during withdrawal were observed by the licensee.
t The fuel vendor evaluated the bearing strees in contact between the zircoloy fuel assembly guide tube, and the inconel-600 CEA fingers. The analytical ,
evaluation concluded that the integrity of the guide tubes and fuel assembly cage were not compromised based on the as-found cos,dition of CEA 131. To supplement the vendor's analysis, procedure ANF 1362(P) was prepared and implemented to inspect fuel assembly M 15. The inspection consisted of verification that the fuel alignment plate slips onto the uppet tie plate without binding; the upper tie plate is level on the alignment plate; verification of proper response to the assembly reaction plate when subjected to an hydraulic pressure, and proper CEA insertion, and withdrawal. No anomalies were noted durir.g the performance of the examination of fuel assembly (M 15) on October 12.
The damaged CEA was replaced one for-one. The CEA and replacement were not of the susceptible design as described in report detail 7.2.1.
The licensee concluded based on the vendor structural analysis results, and confirmation tests to fuel assembly M 15 that it was acceptable for continued reactor core service. Based on this conclusion, fuel assembly M J5 was reinserted into the vessel for cycle 11 operation.
Assessment and Conclusions inspection of this event consisted of discussions with licensee personnel involved in the refuel operations, examinations, and evaluations. The inspection also consisted o' review of NCR 290-264, applicable Final Safety Analysis Report sections, iIR 90-112, OP 2303, AWO M2 90-11861, and AWO M2 90-10572.
Based on discussions with the assigned senior reactor operator during the refeling operation, verificaticn of the spreader "up" indication was noted and the refuel camera was viewed to check for any raised adjacent CEA. The camera however, did not provide a full view of all four sides of the raised fuel assembly. The operator focused on the spreader "up" indication, and with that indication a belief that the spreader was unable to grapple unto the adjacent CEA spider, inspector assessment of procedural implementation of OP 2303 concl .dd that applicable steps 5.7.18 and 5.7.19 were adhered to based on available l
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' equipment; however, procedural detail and or equipment was insufficient of accomplish the visual examination to adjacent CEAs during vertical fuel movement. A strong reliance on spreader limit switch indication was noted with inadequate visual back up review. .
t inspector assessment was that licensee identification and corrective actions to the affected fuel assembly and control element assembly were extensive. The '
assessment was based on vendor support to licensee engineering, and licensee examinations to the affected fuel assembly.
In conclusion, procedural detail and equipment was insufficient to verify that no adjacent CEAs are moved during vertical fuel movement. 'Ihe inspector will review licensee actions to improve OP 2303 in future routine inspections.
Licensee identification and corrective actions were extensive.
9.9 Startun Prenarations and Plant Restart The inspector reviewed bypass jumper lifted leads control log procedure (ACP-QA 206.B) adherence and the on-going plant recovery from the outage. The inspector noted that log entry 2-90-79, temporary shielding, reactor head laydown area, was not cleared although the temporary shielding was no longer being used. The inspector discussed this discrepancy with the shift supenisor who cleared this entry after verifying that it was no longer required. The t inspector reviewed the log for timeliness of audits and documentation of PORC meetings which are required for jumper devices in use for greater than three months. No further log problems or discrepancies with audit timeliness were noted.
The inspector obsened the performance of high pressure safety injection ,
tystem alignment procedure 2604E at Millstone 2. The operator performing : .
the hneup properly verified valve positions and coordinated valve manipulations with control room operators.
Selected equipment tag-outs were reviewed prior to plant start up. Tag-outs 2-25S1-90, 2-2550-90, 2-2688-90, 2 2679 90, 2 2662 90, 2 2629 90, 2-2604 90, and 2-1829 90, were adequate to isolate the equipment and afford personnel safety protection.
To this end, plant restoration from the refuel outage was well imple nented and coordinated, based on inspector review of system status, and observation of startup activities.
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SAMPLE RECORD OF ALLEGATION PANEL DECISIONS SITE: NSc1 PANEL ATTENDEES:
ALLEGATION NO.: T OS . A2 ' T' '* G'8 2 ChairmanN - b. b OATE: 10[f 7[90 (Mtg.h2 3 4 5) Branch Chief - 62 t) (
PRIORITY: High Low Section Chief (AOC) - D. bmA SAFETY SIGNIFICANCE: Yes No Others -
CONCURRENCE TO CLOSE0VT: 00 h SC lt . ww[
CONFIDENTIALITY GRANTED: Yes No hk, d (See Allegation Receipt Report) ()
15 THEIR A 00L FINDING: Yes IS CHILLING EFFECT LETTER WARRANTEO: Yes HAS CHILLING EFFECT LETTER BEEN SENT: Yes h
MAS LICENSEE RESPONDED TO CHILLING EFFECT LETTER:
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. ALLEMTION RECEIPT REPORT 5 Date/ Time
, , Received: lofil.f4o /Y/$ Alregation No k l- TO - [ - 0/M (leave blant)
Name: Address:
Phone: City / State / Zip:
Confidentiality:
Vas it requested? Yes 1 No Was it initially granted? Yes No j Vas it finally granted by the allegation panel Yes No Does a confidentiality agreement need to l>e sent l to alleger? Yes No J
Has a confidentiality agreement been signed? Yes No i Memo documenting why it was granted is att hed? Yes No l
l e O Position / Title Facility: b il \ dm '2- Docket No.: 6d33b (Allegation $uenary (brief description of concern (s): '
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tapi$yee Receiving Allegation: _ )f D. Mic14 -3 . .$ .bfeAt (first two initiali and last name)
Type of Regulated Activity fReactor (d) Safeguards Vendor (e) _ Other:
[ Haterials (Specify) l MaterialsLicenseNo.(ifapplicable):
i FunctionalArea(s): a Operations _e f Onsite Emergency Preparedness
__ b Construction Health and Safety l
[d c Safeguards Transportation
[g Offsite Health and Safety
__ h Other:
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(NRC Region I Fors 207 l- Revised 30/89) .\
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NRC Region I Form 207 (Revised 10/89)
OCT 12 90 13:53 NRC MILLSTONL OFFICE P02 i
l M ACHMENT PDCR 2-029-90 pey. p '
Page 1 of 5
@ DESIGN INPUTS
- 1) Bently Nevada 3300 System Hanual *
- 2) NUSCO Drawing 25203-a) 35001, Lighting Notes and Details b) 34001, Sh. 7,8 9, 65, & 67 Details, Raceway Notes, Symbols, and c) 35038, Sh. 5. Li d) 35008, Li hting,ghting Panel Schedule Panel No. LO8 54 -6" Grounding & Comm. plan, Turbine Building El.
- 3) National Electric Code - 1984 Article 210, Branch Circuits
- 4) Article 348, Electrical Metallic Tubing Standard Ed.; 1978Handbook for Electrical Engineers; Fink and Beaty, lith 5)
Specification InstallationsSP-EE-076, Standard Specification For Electrical 6)
IEEE Specification 383, Cable Description Report, Millstone Unit 2 5.lB DETATLED DESIGN Description The Bently Nevada 3300 Vibration monitoring system is designed for use on fluid film bearing machinery where a significant portion of the shaft vibration is transmitted to the bearing housing. This system consists of a shaft relative proximity probe, bearing housing relative seismic transducer, and dual vibration monitor instrument rack. The':
instrument rack consists of a power supply, system monitor, and 9 dual probe housing.vibration monitors, one for each turbine generator bearing j 32'F to 149The *F instrumentation is rated for an operating temperature of with a humidity of 0 to 95%, noncondensing. Therefore ambient conditions on the turbine building deck are acceptable for installation of the vibration monitoring instrument rack.
The rack.3300 power supply occupies the left most location in the instrument containsIt the provides systemregulated OK relay. power to all monitors in the rack and transducers or field wiring in the system.The OK relay annunciates Because any faulty the relay is normallypower primary denergited, its change of state also will annunciate loss of to the system.
The system monitor checks the voltage supply levels that are vital for all monitors in the rack. proper system operation and is used to ad]ust the alarm setpoints for The 3300 instrument rack receives input from each dual vibration probe mounted at the same relative bearing location of the turbine generator.
The dual probe transducer, transducer mounted togetherconsists in one assembly. of a proximity probe and velocity measures relative shaft vibration and the average shaft position.The proximityThe probe seismic probe measures bearing housing absolute motion.
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4 ALLEGA110N RECEIPT REPORT Date/ Time Received: Oc 419, O w& A11'egation No. NI A - O/P2, (leave blant) .
Name: Address:
Phone. City / State / Zip: .
Confidentiality:
Was it requested? Yes y No Was it initially granted? Yes No Was it finally granted by the allegation panel Yes No Does a confidentiality agreement need to be sent to alleger? Yes No Has a confidentiality agreeseent been signed?' Yes No Memo documenting why it was granted is attached? Yes No e bh4 OLidis Position / Tit) _
Facility: Mdhke L Docket No.: 5'o/335 (Allegation Sumary (brief description of concern (s): /0b d D.A M MOV d o H D r o w ',+ v OV6n. A wak 5
i Number of Concerns: I Employee Receiving Allegation: k AQ~o'b. ik A* /JS b r (first two initials and last name)
Type of Regulated Activity a d Safeguards b _/ Reactor Vendor e _ Other:
c ~ Materials
_ (Spectfy)
Haterials License No. (if applicable):
FunctionalArea(s): '#a Operations ,,_ e Emergency Preparedness b Construction -
f Onsite Health and Safety c Safeguards g Offsite Health and safety (d Transportation ~h Other:
(NRC Region I Form 207 .Inf rmation in this record was de'etea
/ Revised 10/89) m accordance with hh Act, exemptions - e h . m of information F01A 9 1 - h a v ,:,. ,~.; 1
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- FMMS WORK ORDER SYSTEM. **** PAGE 1 ,
PMMS ID.....: M2 02. PL UN L SYS COM SER DEVICC NO. DUILDING. RB
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LOCAL JD....: P2R SVL RLF.2-RC-404 ROOM.....: TOP OF PRESSURI2ER 2-RC-404V i LOCAL SYSTEM: 2301 ELEVATION: 0038 FEET 06 INCHES '
. DESCRIPTION. GRID.....: 2303 PRESSURIZER POWER OPERATED RELIEF VALVE FL YR SERIAL No.
WORK ORDER.......: M2 90 09044 CREATED: MPS27FE 09 / 12 / 90 18490's LEAD DEPARTMENT..: MNTC PRIORITY: 3 CHANGED: MPB27FE 09 / 12 / 90 184905)
WORK ORDER TYPE.. CM '
FREODENCY: UNIT STATUS REQUIRED..: R PERIODICITY: 000 DAYS. ,
WORM ORDER STATUS: 1. 09 / 12 / 90 PLANNING STATUS.: S 09 / 12 / 90 Ph-cLEM DESCRIPTION...: OUTLET FLANGE FASTENERS HAVE A HISTORY OF NOTE:
A SECTION X! REPAIR PLAN IS REQUIRED. PRIOR TO STARTING JOB CONTACT MAINT ENGINEER UNIT ISI COORDINATOR AND ANII SUSPECTED CAUSE:
ORIGINATOR..........: J DIAMOND ORIGINATING DEPARTMENT.........: MNTC DATE ORIGINATED.....:
APPROVAL DATE....... 0009/ / 00 12 // 90 00 184841 TROUBLE REPORT NUMBER....:
SUPERVISOR APPROVAL:
DESIRED REQUIRED SCHEDULED START DATE: 09 / 15 / 90 COMPLETION DATE: 12 / 15 / 90 1 12 PROJECT REFERENCE. SDWL10VLV DESch1PTION:
PRECEDENCE W.O. 31) 2)
ASSOCIATED W.O. 31) 3) 4)
- 2) 3) ,
4)
ITEM NUMBER UPDATE 000001SAVE 8/20=P2 3/15=END OF 000001 i OUT pal *NOSAVE. OF A POSSIDLE 00000I i SEARCH INAC .
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OCT 24 '90 08:48 NRC MILLSTONE OFFICE PO4 UP11PWM6 **** PMMS WORM ORDER SYSTEM.' **** PAGE 1 PL UN L SYS COM EER DEVICE NO. DUILDING. RB FMMS ID...'.: M2 Of. PZR EVL RLF 2-RC-402 ROOM..... TOP OF PRESCURIZER LOCAL ID....: "-RC-40EV LOCAL SYSTEM: 2301 ELEVATION: 0038 FEET 06 INCHER GRID.....: 2383 DESCRIPTION.: FRESCURIZER POWER OPERATED RELIEF VALVE P. YR SERIAL NO. CREATED: MP82TFE 09 / 12 / 90 184019 WORK ORDER.......: M2 90 09843 CHANGED: HP82TFE 09 / 12 / 90 184819 LEAD DEPARIMENT..: MNTC .
PRIORITY: 3 UNIT STATUS REQUIRED..: R WORK ORDER TYPE..: CM FREQUENCY PERIODICITY: 000 DAYS WORK ORDER STATUS: I 09 / 12 / 90 PLANNING STATUS.: S 09 / 12 / 90 PRODLEM DESCRIPlION...:.; OUTLET FLANGE FASTENERS HAVE A HISTORY OF GUALING N.OJFt,A s ECCTION XI REPAIR PLAN IS REQUIRED. PRIOR TO STARTING JOE:
CONTACT MAINT ENGINEER, UNIT ISI COORDINATOR AND ANII SUSPECTED CAUSE:
ORIGINATOR.......... J DIAMOND ORIGINATING DEPARTMENT.........: MNTC DATE ORIGINATED.....: 09 / 12 / 90 184750 TROUBLE REPORT NUMBER....:
APPROVAL DATE....... 00 / 00 / 00 SUPERVISOR APPROVAL:
DES 1 RED REQUIRED SCHEDULED START DATE: 09 / 15 / 90 COMPLETION DATE: 12 / 15 / 90 1 12 / 15 / 90-PROJECT REFERENCE.I SDWLIOVLV DESCRIPTION:
PRECEDENCE W.O.. 1) 2) 3) 4)
ASSOCIATED W.O..t!) 2) 3) 4)
ITEM NUMDER 000001 OF 000001 , OUT OF A POSSIBLE 000001 , SEARCH INACTIVE .
UPDATE 8/20=P2:3/15*END EAVE,PAlaNOSAVE.
nW .a O s' I l 'ON9 P$ 4 $ g
OCT. 24 '90 08948 NRC MILLSTONE OFFICE P03 UP11PWMO **** F MMS WORK ORDER SYSTEM. **** PAGE 1 FL UN L SYS COM SER DEVICE NO. DUILDING.: RB J' MMS ID.....: MO O2 PZR SOV RLFi2-RC-404 LOCAL ID.... ROOM.....: TOP OF FRESEURIZER E-RC .04 ELEVATION: 0038 FEET 06 INCHEst LOCAL LYLTEM: 2301 GRID.....: 2393 DESCRIPTION.: FRESSURIZER POWER OPERATED RELIEF VALVE ASSEMBLY PL YR SERIAL NO. CREATED: MP82TFN 04 / 21 / 69 165TEC WORK ORDER.......: M2 89 05344 LEAD DEPARTMENT.. MNTC CHANGED: MPS2TE1 08 / 25 / 90 113804' PRIORITY: 3 UNIT STATUS REOUIRED..* R WORK ORDER TYFE..: PM -
FREQUENCY: R PERIODICITY '545 DAYS WORK ORDER STATUS: I 03 / 24 / 90 PLANNING STATUS.: G 00 / 25 / 90 FROBLEM DESCRIPTION...: . REFUEL PM (MECHANICAL)
SUSPECTED CAUSE:
ORIGINATOR.......... J STANSDURY ORIGINATING DEPARTMENT.........: MNTC DATE APPROVAL ORIGINATED.....: 04 / 21 / 89 165T16 TROUBLE REPORT NUMBER....:
DATE.......: 00 / 00 / 00 SUPERVISOR APPROVAL:
-DESIRED REQUIRED SCHEDULED START DATE .09 / 15'/ 90 COMPLETION DATE: 12 / 15 / 90 1 12 / 15 / 90 PROJECT REFERENCE.: SDWL10VLV DESCRIPTION:
PRECEDENCE W.O.. 1) 2) 3) 4)
ASSOCIATED W.O..:1) 2) 31 4)
ITEM NUMBER 000001 CF 000001 .
OUT OF A POSSIBLE 000001 CEARCH INACTIVE ,
UPDATE 8/20aP2:3/15=END SAVE pal =NOSAVE.
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