IR 05000395/1980025
| ML19353A349 | |
| Person / Time | |
|---|---|
| Site: | Summer |
| Issue date: | 10/06/1980 |
| From: | Kellogg P, Skolds J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19353A343 | List: |
| References | |
| 50-395-80-25, NUDOCS 8101080248 | |
| Download: ML19353A349 (13) | |
Text
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UNITED STATES s.
?o NUCLEAR REGULATORY COMMISSION
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101 MARIETTA sT N.W., SUITE 3100
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ATLANTA, G EoRGI A 30303
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Report No. 50-395/80-25 Licensee: South Carolina Electric and Gas Company Columbia, South Carolina 29218 i
Facility:
V. C. Summer Docket No. 50-395 License No. CPPR-94 Inspection at V. C. Summ r near Winnsboro, South Carolina Inspector:
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ot u J. L. Skol s
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Dath S'gne Approved by:
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/l SUMMARY
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Inspection on July 21, 1980 - August 31, 1980 Areas Inspected This routine inspection by the Resident Inspector involved 300 inspector-hours on site in the areas of preoperational test procedure review, operating procedure review, FSAR review, proposed Technical Specification review, preoperational test observation, plant tour, review of 50.55(e) reports.
Results
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Of the seven areas inspected, no items of noncompliance or deviations were identified in six areas; one iten of noncompliance was found in one area (Infraction -
failure to follow procedure - paragraph 9.d.).
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DETAILS 1.
Persons Contacted
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Licensee Employees
- 0. S. Bradham, Plant Manager
- J. G. Connelly, Assistant Plant Manager S. Smith, Maintenance Supervisor L. Storz, Operations Supervisor D. Moore, Manager QA
- A. A. Smith, Site QA Coordinator A. Keen, Technical Staff Engineer B. Croley, Technical Support Supervisor
- K. Woodward, Assistant Operations Supervisor Attended exit interview.
2.
Exit Interview The inspection scope and findings were summarized on 8/1, 8/15 and 8/24 with those persons indicated in Paragraph I above. The item of noncompliance was discussed at the exit interview on 2/29/80. The inspector also attended the exit interview of B. Kleinsorge and H. Whitener on 8/8/80, K. Walters and N. Merriweather on 8/15 and E. Ford and H. Whitener on 8/29/80.
3.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (395/80-15-06) Failure to establish measures to a.
control changes to the procurement document after a purchase order is placed. The inspector reviewed the response to this item dated July 28, 1980. The response indicates in the "cause" section that procurement document changes were, in fact, being routed to all originally involved organizations for review. This statement is misleading because the changes identified by the inspector were QA changes, which were part of the procurement document, yet were not reviewed but rather returned to the procurement files. The procedure changes made in the area of procurement document changes were reviewed by the inspector and found to be acceptable.
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b.
(Closed) Noncompliance (395/80-15-07) Failure to follow procedure concerning relief valve setting and covering of snubbers. The inspector reviewed the response to the item of noncompliace dated July 28, 1980.
A memo from the Start-Up Supervisor to all test supervisors dated May 22, 1980 was also reviewed. The corrective action for the relief valve setpcint tolerance appears to be adequate. The inspector reviewed the plan for keeping mechanical snubbers covered red noted that all snubbers were being kept covered in the plant.
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4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Preoperational Test Procedure Review The inspector reviewed the following preoperational tests:
a.
VB-1 Vibration Test b.
SI-8 ECCS Leak Check c.
BD-1 Steam Generator Blowdown The procedures were reviewed to ensure they were technically adequate and to ensure they were consistent with the commitments made in Chapter 14 of the FSAR and with Regulatory Guide 1.68.
The inspector had the following comments concerning the tests:
VB-1 Section 3.9 of the FSAR describes the Vibration Test Program.
Section 3.9.1.1 states that the specific conditions under which vibration will be observed are as follows:
a.
Design flowrate b.
Minimum flowrate (shutoff flow)
c.
Maximum flowrate (runout flow)
d.
Startup e.
Shutdown f.
Other specific transients The inspector observed that vibration readings are not specifically being taken at design flowrate or runout flow. The inspector informed the applicant that the test program would have to include these. conditions or the FSAR would have to be amended.
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Section 3.9.1.1 also indicates that specific attention will be directed
toward evaluating possible vibration problems during the main steam safety i
valve blowdown. The inspector questioned whether the safety valves were going to be lif ted during preoperational testing. The applicant indicated l
this commitment would be reconsidered.
l VB-1 tests each Motor Driven Emergency Feedwater Pump separately but does l
not evaluate the vibration when both pumps are running together. If emergency feedwater is needed and the system operates as designed, both motor driven
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.I emergency feedwater pumps will start. The applicant indicates that vibration observations would be made with both pumps running.
The Spent Fuel Cooling Pumps will not be observed since they will not be run until the Spent Fuel Pool can be flooded.
The procedure did not include testing of both Reactor Make Up Pumps.
I The above items will remain open (80-25-01) peeding further inspector review.
SI-8 i
Numerous ster.s in the procedure involved measuring leakage upstream of a j
check valve with no pressure applied downstream. This occurred when measuring leakage past the second check valve in the safety injection line from the Reactor Coolant System. The procedure was changed to apply pressure downstream of the second check valve.
BD-1 Step 6.7.17 verifies that valve 4701A closes when a high pressure alarm is received from PT 4707A. The instrument list indicates that the high pressure alarm occurs at 125 psig and the high pressure closure occurs at 150 psig.
This item will remain open (80-25-02) pending further inspector followup.
6.
System Operating Procedure Review The inspector reviewed the following System Operating Procedures (SOPS):
SOP-101 Reactor Coolant System SOP-102 Chemical and Volume Control System SOP-117 Service Water The procedures were reviewed for technical adequacy and conformance to regulatory requirements. The inspector was aware that Technical Specifications, operating limits and setpoints are still being changed and this may cause a procedure to be in error. The procedures were adequate with the following exceptions:
SOP-101 Step Comment 3.5.2.B How does-operator verify shaft rotation?
3.5.2.C How is six per day being tracked?
3.5.2.F Once the vibration level has reached.015 inches and vibration is increasing 001-inch per hour,
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shut down the pump. Is this increasing vibration an average rate of increase? If the vibration has
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3.5.2.G Some comment as in 3.5.2.F except this step addresses frame vibration and the numbers are smaller.
3.5.3.A This step sets a high bearing temperature limit on RCP's of 200 degrees Fahrenheit. The RCP Techneial Manual recommends tripping the RCP at a bearing temperature of 195 degrees Fahrenheit.
3.5.3.B The word " idle" should be omitted from this paragraph and the RCS temperature limit should be 150 degrees Fahrenheit vice 450 degrees Fahrenheit.
3.5.4 Indicates a seal injection water supply temperature limit of 130 degrees Fahrenheit. The Westinghouse PLS says 135 degrees.
Indicates a seal injection flow limit of 6 to 13 gpm to each pump. Westinghouse PLS indicates 6 to 12 gpm.
3.7 Indicates Oxygen must be in specification before exceeding 180 dcgrees Fahrenheit.
The proposed Technical Specifications indicate oxygen must be in specification before exceeding 250 degrees Fahreheit. Although the procedure is more conser-vative, the Technical Specifications and the S0P should agree in this case because other documenta-tion such as the Westinghouse Chemistry Manual recommends 180 degrees Fahrenheit.
3.11 Indicates a maximum heatup rate for the pressurizer of 200 degrees Fahrenheit per hour. The proposed Technical Specifications state 100 degrees Fahrenheit per hour.
4.1.3.F Indicates it is allowable to close the RCP seal bypass valve (8142) when all flow recorders indi-cate seal leakoff greater than 1 gpm. There is no mention of the requirement that pressure be greater than 1000 psig.
4.1.4.C Should read TE-453 vice 433 4.3.2 The wrong valve is opened. Valve 8069 B is opened instead of 8069A.
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5.2.6, 5.2.16, 5.3.9 Refers to PVG-1003. Should be LCV 1003 5.5.6, 5.8.6 Does not specify how much room is necessary to drain the loops to the BRHUT.
5.5.6, 5.8.6 Indicates starting a CHV/SI pump per steps 4.1.1 through 4.1.5 of SOP-102. These steps don't start the CHV/SI pump.
5.6.3 Indicates starting a RCP per Section 4.2 of SOP-101.
This section does not start a RCP.
5.6.11 khat is the scope of this step? Does it include all instrumentation associated with the RCS?
5.7.17 Indicates draining the PRT to the lowest operating level. What is the lowest operating level and why not specify this level in the procedure?
6.1.4.D Wrong Technical Specification reference Various portions of Various steps in Section 6 refer to reducing Section 6 power to 20% prior to securing a RCP. What is the basis for the 20% power?
i 6.2.3.C What is HCV 1227 (FCV 122 or : ICV 186)
Attachment I Valve 8076 (tell tale isolation off vessel flange leakoff) is omitted.
All valves on the RTD manifold plus valves 8082 and 8085 were omitted but added by testing personnel during HFT.
Attachment III The following parameters have incorrect minimum and/or maximum limits listed: Primary pressure, primary temperature, No. 2 seal flow, No. 2 seal differental pressure, No. 3 seal flow, No. 3 seal differental pressure, thermal barrier cooling water flow, upper bearing cooling water flow, upper bearing cooling water inlet pressure, lower bearing cooling water flow.
These items will remain open (80-25-03) pending further inspector review.
SOP-102 Step Comment 4.1.1.B This step requires 20 i 2 psig in the VCT as a prerequisite.
The preoperational test sets the pressure regulator for 25 psig.
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I 5.4 Technical Specification reference is incorrect.
5.5.9 Incorrect steps referenced.
5.6.12.B Should read valve 8376.
5.8.3 Should o ad 8524B vice 8522B.
5.8.4 Valve 8514 should be throtted or closed when j
placing the cation demineralizer in service
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Attachment I Valves 8513, 8441 - drawings indicate valve (valve
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line up) is locked closed. Procedure just requires
closure.
s Valve 8421 should be closed not open on initial lineup.
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The CHV/SI pump suction and discharge valves (8471A, B, C and 8485A, B, C) are called for to be locked open on the drawing. The valve lineup just j
requires open.
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Valve 8392 (Bypass around 8146) is called for to
be locked open on the drawing. The valve lineup
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just requires open.
t Valves 8353A, B, C, 8357A, B, C, 8541A, B, C are i
called for on the valve lineup but don't exist.
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Valve 8142 is titled incorrectly.
Omitted valve 8457. This valve does not appear in the Reactor Makeup Water valve lineup.
Valve lineup opens LCV 459 and 460 then the 1st step of the procedure calls for them to be closed.
a Attachment II (valve lineup in the Reactor Building)
is never referenced in the procedure.
i 4.2.5 Requires a minimum of 100 psid across #1 seal.
Should read 200 psid.
4.3.1.D-Should read Attachment IIl-i
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There are numerous drain valves with no assigned numbers that do.not appear on the valve lineup.
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-7-These items will remain open (80-25-04) pending further inspector review.
SOP-117 Step Comment 3.1 Requires 415 feet in Service Water Pond. Control Room readout is 0-16 feet.
4.1.3 Gives amperage limit for slow speed operation but none for fast speed.
4.2. 6, 5.1. 7, 5.5.2. C Refers to wrong step 5.4.8 After backflushing a CCWHX, this step requires a valve lineup. This appears unnecessary and could possibly lead to errors.
6.2 Should verify flow through FE-4466 or FE-4496 when Service Water Booster Pumps start There is no section in this procedure to manually operate the screen wash system.
Attachment I Needs to be arranged for operator convenience.
(Valve Line Up)
Omitted valves 3178, 3175, 3176 and 2 isolation valves for FT 4493.
These items will remain open (80-25-05) pending further inspector review.
7.
FSAR Review The inspector reviewed commitments made in the Questich and Answer Section of the FSAR. In particular the inspector reviewed the responses to the 211 Series of Questions.
The inspector had the following comments:
Question 211.5 states that the CRDMs are safety related.
a.
The inspector questioned whether the mechanisms are safety related.
b.
Question 211.7 states that component testing will be performed on the main steam and pressurizer safety valves cs an integral part of specific system tests.
The inspector could find no safety valve testing in the preoperational test program.
Question 211.21 indicates that offsite doses will be within 10 CFR 100 c.
limits, provided the leak is isolated within 15 minutes assuming a 50 gpm leak.
The inspector indicated that the annunciator response procedures would be reviewed to determine whether the 15 minute estimate
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d.
Question 211.39 has numerous inconsistencies with the GOP's and E0P's.
(1) The nu=ber of charging pumps taken out of service at less than 1000 psig does not match GOP-6.
(2) There is an inconsistency between the response to this question, the GOP's and the proposed Technical Specifications concerning whether the charging pumps are locked out and tagged whether the breakers are racked out or whether the switches are placed in pull to lock when less than 1000 psig (3) The response to the question states that the operator will not cool the plant down to 425 F before reducing pressure below 1000 psig. This statement could not be found in any operating procedure.
(4) The response to the question indicates that the operator will reinstitute power to the accumulator isolation valves and the locked out CHV/SI pump in the event of a LOCA at low pressure.
This could not be found in ary emergency operating procedure.
e.
Question 211.47 states that hot leg recirculation will commence 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> af ter a LOCA and thereafter on 24-hour cycles. E0P-1 and SOP-112 states that hot leg recirculation occurs 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> af ter a LOCA.
f.
Question 211.48 indicates that a number of valves have " locking provisions".
Some of these valves listed are called for to be locked by a procedure's valve lineup, some do not require locking by the valve lineup. The inspector requested the applicant to clarify what is meant by " locking provisions" taking into account that nearly all valves can be " locked" in one way or another.
These items will remain open (80-25-06) pending further inspector review.
8.
Proposed Technical Specification Review The inspector reviewed a change to the proposed Technical Specifications for clarity and enforceability. The inspector had the following comments:
a.
The inspector recommended not using cubicle numbers in listing the penetration overcurrent devices.
This would preclude changing the Technical Specifications in the future when a spare Weaker is used.
b.
Page 3/4 4-2, Section 4.4.1.2.2.
states that at least two reactor coolant loops, if not in operation, shall be determined to be OPERABLE once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in Mode 3.
If the operability of a RCP is not necessary to make a Reactor Coolant Loop operable, what criteria is going to be used to determine whether a reactor coolant loop is operable?
Page 3/4 4-3 states that 1288 cubic feet is required in the pressurizer.
c.
This figure needs to be expressed in per cent level so that the operators are able to relate this figure to the control board meter.
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Page 3/4 4-17 changed controlled leakage limit to 33 gpm. The inspector questioned the basis for this change.
Page 3/4 7-4 changed the discharge pressure and flow requirements in e.
the Surveillance Section of the Emergency Feedwater Pumps.
These numbers do not correspond to any preoperational testing the inspector has reviewed.
f.
Page 3/4 7-15.
The section on control room ventilation indicates that there is no requirement to maintain a positive pressure in the control room during emergency operation. The Technical Specifications do not address the situation where the control room is placed on 100% recir-culation and the outside air supply is isolated.
These items will remain open (80-25-07) pending further inspector followup.
9.
Preoperational Test Observation The inspector observed portions of the following tests:
MS-1 Atmospheric Steam Dump EF-1 Motor Driven Emergency Feedwater EF-2 Turbine Driven Emergency Feedwater MS-2 Steam Dump RC-7 RCP HFT Data TE-1 Thermal Expansion Test RC-1 Hot Functional Test The inspector observed the tests to ensure procedures were being followed, the testing was being performed under properly controlled conditions and to independently verify the test results. Findings were acceptable with the following exceptions:
Communications between control room operators and test personnel in a.
the plant is poor. Operators resort to shouting into the sound powered phones or using the page phones to conduct the tests.
Tne Reactor Coolant Pumps were run for a number of days with the following alarms present: RCP Motor Overload (A and C pump), CCW High Temperature (A, B and C pumps), RCP B seal leakoff low flow, RC Loop B low flow alarm. Although actual alarm conditions did not exist in any of the above cases, the alarms were present and therefore if an actual alarm condition did exist, the operators would have been unaware of the condition unless the operator was observing the specific alarming parameter. Not enough effort was expended in clearing these alarm conditions by plant personnel since once the inspector questioned the existence of the alarms, they were cleared in a short period of time.
Although none of these alarms presented any technical problems with the RCP's, operating major pieces of equipment with alarms disabled is a poor operating practice.
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-10-The RCP seal injection flow meters had a temporary scale taped over the original scale. However, the new scale was not marked and the new scale was not understood by operators and test personnel. The operators were using the cathode ray tube available in the control room which displays various computer points.
The above items will remain open (80-25-08) pending future control room observations by the inspector.
b.
The Reactor Building average temperature during HFT has been between 115 degrees Fahrenheit and 120 degrees Fahrenheit.
The Technical Specification limit is 120 degrees Fahrenheit. The Reactor Building is running hotter than expected with 3 of the 4 Reactor Building Cooling units in service. To maintain the temperature less than 120 degrees Fahrenheit, the fourth cooling unit has to be used. Engineering evaluations are being performed to determine the cause and the solution.
This item will remain open (80-25-09) pending inspector review of the disposition of this problem, In the performance of the tests on the Steam Driven Emergency Feedwater c.
Pump, it became evident that the pump could not deliver 190 gpm to each of two steam generators when Reactor Coolant Temperature was 350 degrees Fahrenheit and steam pressure is 100 to 120 psig. Data obtained at this condition indicate the pump can only deliver the following:
"A" S/G - 180 gt.n
"B" S/G - 205 gpm
"A" S/G - 170 gpm
"C" S/G - 240 gpm Section 10.4.9 of the FSAR states that the system is designed to deliver feedwater, at a minimum flow of 190 gpm to each of two steam generators pressurized to 1211 psig.
An engineering evaluation is being performed to determine if the flow is adequate.
l This item will remain open (80-25-10) pending inspector review of the engineering evaluation.
d.
In reviewing the valve lineups performed in accordance with RC-1 " Hot Functional Testing", the inspector noted that the valve lineup for SOP-102 " Chemical and Volume Control" could not be located.
The testing personnel and operators then proceeded to perform a valve lineup. To expedite the valve lineup the individual performing the valve lineup noted that if a flow transmitter was working and indicating flow the isolation valves must be open. He als. remembered a change made to the RCP #2 seal standpipe level indicator and thought that certain valves had been removed. The Startup Manual, Section SUM B-8,
" Conduct of Start Up Testing" Section 3.4 states that initialing a step in a procedure indicates that based on personal observation or
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-11-reports from assigned test perronnel, the step has been performed as written, conditions are as describsd and results are as recorded. The individual performing the valve liceup initialed valves 8353A, B and C, 8357 A, B and C as open because the flow transmitter associated with these valves was working. However, these valves were removed some time ago and do not exist in the system. Valves 8540 A, B and C were crossed off and initialed as "N/A" when in fact these valves exist and were closed. These items are considered to be an apparent item of noncompliance (80-25-11).
In the performance of the heatup and pressurization of the RCS, the e.
primary to secondary differential pressure limit of 1600 psid was exceeded by about 250 psi. An engineering evaluation is being performed to assess the consequences of this event. This item will remain open (80-25-12) pending inspector review of the engineering evaluation.
10.
Plant Tour The inspector toured the plant at various times to observe construction activities, housekeeping, maintenance, equipment preservation and log books. Findings were acceptable with the following exceptions:
The inspector found that the local indication of differential pressure a.
across the Reactor Coolant Filter in the letdown line was 105 psid on August 4, 1980. The design differential pressure is 7.5 psid. Other filters in the charging and seal injection system were being monitored by operations personnel but this filter was omitted. The inspector found that there is no guidance for operators to follow to determine when a filter is to be changed out. This item will remain open (80-25-13)
pending future review by the inspector.
b.
On August 27, 1980, the inspector noted that CCW Booster Pump "C" was running hot. Operations personnel subsequently secured the pump and generated a maintenance work request.
The inspector toured the Fuel Handling Building to observe security c.
and housekeeping. The housekeeping in the Fuel Handling Building was poor due to work being performed around ;.he Reactor Building. The poor housekeeping did not present an immediate danger to the fuel being stored in the building but indicated poor housekeeping practices associated with the work in the area. The license stated the house-keeping in the area would be improved.
11. IEB Followup The inspector reviewed the response to IEB-80-05 " Vacuum Condition Resulting in Damage to Chemical Volume Control System Holdup Tanks". The response states that "all tanks have an open line to the plant atmosphere or an open line directed to the plant vent system to preclude a tank vacuuri condition from existing. No valves are installed in these vent lines". This statement was meant to apply only to the types of tanks mentioned in the IEB and not till the tanks the Bulletin directed to be reviewed.
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Attachment I to the response indicates that the vent size on the pressurizer relief tank is 3/4 inch. This is true for the manual vent line which is normally closed and has a blank flange installed. However, since the line is closed and blanked, this information is irrelevant and does not indicate anything about the PRT's ability to withstand vacuum conditions. Preopera-tional tests have indicated that the gas system used to blanket the PRT is adequate to prevent drawing a vacuum when the tank is being pumped down at the maximum rate.
The inspector was satisfied that with the above items clarified, the response to the IEB is adequate and the IEB is considered closed.
12. 50.55(e) Reports The inspector reviewed the following 50.55(e) reports:
Incorrect flange material was identified on seven Westinghouse flanges.
a.
316 stainless steel flanges were supposed to be used. 304 stainless steel was used instead. This item will be designated 80-25-14 until closed.
b.
ASME Class 1 pipe was supplied, accepted and installed without the required 4-way ultrasonic examination required by Regulatory Guide 1.66. This item will be designated 80-25-15 until closed.
13. Meetings The insrector participated in the following meetings conducted by NRR at the site:
Emergency Planning Meeting and Public Hearing, July 21-21, 1980 a.
b.
Human Factors Ev7.luation, August 25-29, 1980
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