IR 05000397/1982006
| ML20052J018 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/21/1982 |
| From: | Dangelo A, Dodds R, Elin J, Fox D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20052J013 | List: |
| References | |
| 50-397-82-06, 50-397-82-6, IEB-78-12, IEB-79-03, IEB-79-3, IEB-80-05, IEB-80-08, IEB-80-09, IEB-80-11, IEB-80-16, IEB-80-5, IEB-80-8, IEB-80-9, IEB-81-02, IEB-81-03, IEB-81-2, IEB-81-21, IEB-81-3, NUDOCS 8205240321 | |
| Download: ML20052J018 (23) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No. 50-397/82-06 Docket No. 50-397 License No. CPPR-93 Licensee. Washington Public Power Supply System P. O. Box 968 Richland, Washington 99352 Facility Name: Washington Nuclear Project No. 2 (WNP-2)
Inspection at: WNP-2 Site, Benton County, Washington Inspection conducted: March 1-5 and fiarch 15-19, 1982
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M Inspectors:
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/ Date Signed J. 0. Elin,' Reactor Inspector crim /
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'A. D ' An g
, Reactpf Inspector Dat6 Signed Y'1M fY
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2-1). Fo x, Re orInspepor,RegiogIV
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- l h h2 k V Y2'/W R. T. Dod'ds, Chief, Reactor Projects Section 2 Date Signed Approved by:
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b R. T. Dodds, Chief, Reactor Projects Section 2
' Dat'e Signed Reactor Construction Project Branch Summary:
Inspection during the period of March 1-5 and March 15-19, 1982 (Report No. 50-397/82-06)
Areas Inspected:
Routine unannounced inspection by regional based inspector of activities associated with design control and verification, concrete expansion anchor installation, and various bulletin, circulars, NRC followup items and licensee event reports.
The inspection activities involved 162 inspector-hours onsite and 31 inspector-hours in the regional office by four NRC inspectors.
Resul ts :
No items of noncompliance or deviation were identified.
8205240321 820426 PDR ADOCK 05000397 O
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DETAILS 1.
Persons Contacted Washington Public Power Supply System (WPPSS)'
a.
+*C. S. Carlisle, Deputy Project Manager
-+*R. T. Johnson, Project Quality Assurance Manager
- L. J. Garvin, Manager Quality Performance
- J. R. Honekamp, Managing Directors Office
- P. Harness, Project Engineering
- D. Myers, System Engineering
- B. A. Holmberg, Project Engineering Manager
- D.
C. Timmins, Project Director's Staff
+ W. G. Keltner, Assistant Construction. Manager
+ L. Floyd, Quality Assurance Engineer.
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R. Hamelton, Ouality Assurance Engineer
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C. Park, Civil Quality Assurance Engineer
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A. Yea, Safety Engineer
T. Keheley, Systems Engineer
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J. Yatabe, Systems Engineering Manager b.
Bechtel Power Corporation (BPC)
- T. A. Mangelsdorf, Project Manager
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- D. R. Johnson, Manager of Quality
- J. Curtis, Project Field Engineer
- R. Davis, Quality Assurance Engineer
- G. Ross, Quality Assurance Engineer
+ M. Jacobson, Project Quality Assurance B. Young, Radiograph Interpreter c.
Burns and Roe, Inc. (B&R)
+*L. D. Noble, Project Engineer
- J. W. Tritz,-Project Engineer
+*H. R. Tuthill, Engineering Quality Assurance Manager J. Twomey, Civil Engineer D. Brown, Civil Engineer R. Sanan, Civil Engineering Manager L. Hyde, Civil Engineer A. J..Bagocius, Assistant Manager, Drafting G. W. Brastad, Froup Supervisor, Electrical /I&C W. G. Conn, Senior Group Supervisor J. A. Forest, Project Director S. L. Giannini, Senior Engineer ti. S. Harris, Mechanical Engineer G. Hudak, Engineering Quality Assurance ti. J. Klym, Project Administrator A. N. Kugler, fianager, Engineering T. R. McKinney, Group Supervisor, tiechanical J. McHenry, Squad Leader, Design & Drafting J. Smith, Project Administration J. J. Verderber, Project Engineering Manager W. Webb, Technical Support, Design & Drafting I
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MCC Powers Corporation-
- J. R. Sheldon, Project' Engineer
- B.
Crea, Seismir 'qineer
- R.
Ellis, Proje nager J. Harmon, Corp Jality Assurance Manager R. Jensen, Pro'
'ity Assurance Engineer M. Scott, Seis er
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(e) The Waldinger C (JWC)
- G.
T. Wells, et Manager ( f)
P_eter Kewit and Son's Inc. (PKS)
J. Hunt, Lead Quality Assurance Inspector
+ Denotes those attending the exit interview on March 5,1982.
- Denotes those attending the' exit interview on March 19, 1982.
2.
Bulletins The inspector examined the licensee's action and response to the following IE Bulletins and determined that appropriate corrective action had been initiated unless otherwise indicated.
a.
IEB-78-12 - Atypical Weld Material in Reactor Pressure Vessels General Electric and Chicago Bridge and Iron met with the NRC to resolve atypical weld concerns on a generic basis. Their response was provided to the Commission in a generic report dated May 1, 1979. The licensee also responded to the bulletin on May 25, 1979.
The vessel manufacture has reviewed the records of low alloy, high tensile weld deposits used on all reactor pressure vessels built in their or their supplier's facilities and did not find any
" atypic al weld material." This was specifically atested to in a certif1:ation by CBI Nuclear Company dated April 30,1979 for the Hanford II vessel. This item is closed.
b.
IEB-79-03 - Longitudinal Weld Defects in ASME SA-312 Type 304 Stainless Steel Pipe The licensee stated in response ELE-KAH-80-050 dated October 30,-
1980 that this type pipe had no design stresses greater than 85%
of ASME Code allowable. A program was established to etch the ends of 17 downcomer stub extensions.
In letter G02-81-246 the licensee reported that no lack of centerline penetration was identified.
The certification and interoffice memorandum examined by the inspector confirmed the reported information. Also, letters were issued to the contractors directing that stresses be no greater than 85% of ASME Code allowable for this type pipe for thickness determination. This item is close.
h.
IEB-80-05 - Vacuum Condition Resulting in Damage to Chemical Volume Control System Tanks The subject bulletin was reviewed by the licensee and determined not to be applicable since there are no analogous situations at WNP-2. This item is closed.
i.
IEB-80-08 - Examination of Containment Liner Penetration Welds The licensee determined that flued head fittings were used on WNP-2 as indicated in the attachment to the response.
It was determined that all welds had been radiographed and are acceptable.
This item is closed.
J.
IEB-80-09 - ITT Hydromotor Actuator Deficiencies The licensee has identified the suppliers who could have used the subject actuators but has not yet received a response from all of the suppliers as to the design of the actuators or use of incorrect spring material.
This item remains open.
k.
IEB-80-ll - Masonary Block Walls It was ver'fied by an examination of licensee's interoffice memorandum F-80-2990 and a Burns and Roe letter dated February 5, 1981 that no safety-related masonary walls have been installed.
However, some removable shielding block walls will be installed between steel plates in the proximity of Class 1 piping in the reactor building. These walls were evaluated to assure that they could withstand a combination dead load plus seismic load resulting from a safe shutdown earthquake.
This item is closed.
1.
IEB-80-16 - Potential Misapplication of Rosemount 1151 and 1152 Pressure Transmitters Burns and Roe issued PED 220-I-656 and 220-I-662 to specify the use of the circuit board type "E" to correct the problem as noted in BRWP-R0-82-78 dated flarch 4,1982. to prevent ambiguous transmitter output signal during over-ranging condition in'conformance with the licensee's response to the f!RC dated August ~18,1980 ( ELE-KAH-80-012). This item.is closed.
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IEB-80-21 - Valve Yokes Supplied by Malcon Foundry Company (Crack Factures)
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As indicated in the licensee'.s final response letter G02-81-341 of October 6,1981, the review ~of. letters from manufactures and the licensee's review of certified documentation packages shows that none of the valves at the project have components manufactured by Malcom Foundry. This item is closed.
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IEB 81-02 - Failure of Gate Type Valves to Close Against High Differential Pressure The records show that the licensee has. examined the WNP-2 safety-related systems and determine that no Westinghouse or Borg-Warner motor-operated gate valves indicated in the bulletin will be used at this facility as stated in licensee responses G02-81-81 and G02-81-301. This item is closed.
o.
IEB-81-03 - Clam Infestation of Water Systems The licensee's response to the subject bulletin dated July 6,1981, indicates that the investigations conducted to date do not indicate that fouling of systems by clams will be a problem but that this area will continue to be monitored.
If the monitoring identifies a potential problem, a specific program will be established to examine critical plar.t equipment. This item is closed.
3.
Circulars The inspector examined the licensee's review of the following circulars and determined that corrective action appropriate to the situation identified in the circular had either been accomplished or identified and assigned to a responsible party unless otherwise indicated.
a.
IEC-79-11 - Misoriented Reactor Pressure Vessel Special interface meetings have been held to assure the compatibility of AE/NSSS design.
This item is closed.
b.
IEC-79-18 - Proper Installation of Target Rock Safety Valves Not applicable.
This item is closed.
c.
IEC-79-20 - Failure of GTE Sylvania Relays A memorandum to the WNP-2 plant manager requires the establishment of an inspection program for these relays. This item is closed.
d.
IEC-79-22 - Stroke Times for Power Operated Relief Valves Not applicable. This item is closed.
e.
IEC-80-04 - Securing of Threaded Locking Devices on Safety-Related Equipment The Operations Superintendent has been notified of the potential problem and a recommendation made that appropriate specific measures be taken in the maintenance program to identify susceptible equipment and check for this condition. This item will be examined during the review of operating maintenance procedure r-6-f.
IEC-80-05 - Diesel Generator Lube Oil Requirements The licensee has determined that the information relating to the consumption of fuel oil at Kewaunee indicates lube oil consumption for the diesel engines may be in excess of-the licensee's present storage capacity for the required seven day operation as specified in.the FSAR (9.5.7.3).
This item remains open pending completion of the licensee's evaluation.
g.
IEC-80-07 - Problems with HPCI Turbine Oil System WNP-2 uses motor driven rather than HPCI steam driven turbines.
This item is closed.
h.
IEC-80-08 - BWR Technical Specification Inconsistency RPS Response Time Not applicable. This item is closed.
i.
IEC-80-ll - Emergency Diesel Generator L' be Oil Cooler Failure u
The required information concerning the use of corrosion. inhibitors has been included in the operating maintenance manual for the diesel-generators.
This item is closed.
j.
IEC-80-12 - Valve-Shaft-To-Actuator Key Orientation The licensee has completed a review of all valve and motor operator designs used at WNP-2 and determined that the valve-shaft-to-actuator keys are positively retained. This item is closed.
4.
Licensee Action 'on 10 CFR 50.55(e) Reportable Deficiencies a.
(Closed) Soil Compaction Problem NRC was informed by the Supply System of a potentially reportable condition concerning Quality Class I soil backfill settlement properties.
The licensee's reports to NRC are contained in Supply System letters; G02-81-0083 dated April 22,1981, G02-81-0262 dated September 1,1981 and G02-81-462 dated November 12, 1981.
The technical evaluation of the licensee's response has been preformed by Hydrologic and Geotechnical Engineering Branch, Division of Engineering, NRR and ne programmatic aspects that permitted the improper compaction of backfill to occur were e ~'t.ated by Region.
-7-Peter Kiewit Sons' (PKS) contract no. 210A is the only contractor at WNP-2 who would be doing any Quality Class I soil backfilling or compaction and, at the present time, the only remaining Quality Class I work is for excavation, backfilling and compaction of soil adjacent to piers for the support of the siphon between spray ponds. No soil backfill and compaction work is presently scheduled for support of Seismic Category I buildings.
PKS procedure CP-5 titled " Soil Excavation Backfilling and Compaction" was examined for the inspection and documentation requirements to prevent recurrence of backfill and soil compaction problems.
PKS procedure CP-5 contains the acceptance criteria for all backfill material used and required in-place density measurements to be taken.
Required sieve analysis and relative density tests.are recorded on checklists numbered QCF-201 and QCF-204.
This item is closed.
b.
(Closed) Cracked Terminal Posts on 250 Volt Station Battery On December 29, 1981 the licensee sent a report of a reportable condition under 10 CFR 50.55(e) to NRC Region V (G02-81-0558).
The 250 volt Class IE battery had been incorrectly installed by the 218 contractor and over torquing of terminal bolts had caused severe deformation of at least two terminal posts.
The Exide representative upon inspection of the battery recommended replacement for the following reasons:
(1) the battery had been left on open circuit without proper maintenance for better than 21/2 years and present voltage readings show several cells with low float voltages, and (2) all cell posts were deformed from over terquing with two cell posts stress fractured.
On the manufacturer's recommentaticn the Supply System (Test and Startup) will purchase a new battery.
This item is closed.
5.
Licensee Action on Previous Inspection Findings and Enforcement Items.
a.
(Closed) Unresolved Item (50-397/81-09/02) Subcontractor Design Control During a previous inspection (IE Inspection Report No. 50-397/81-09)
the inspector found that MCC Powers did not produce design calculations and design drawings for several Quality Class I supports for instrumentatio installed by MCC Powers.
The licensee has now taken the position that the supports in the above stated inspection report were a temporary installation and installed for the " temporary winter heat program".
In the course of the present insnection, the inspector asked for documentation which would identify the supports as temporary since there was no visual indication on the support such as a tag or markin.
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The inspector, during the present inspection, did not receive the requested documentation. However, the licensee will examine the 216 (HVAC) contractors records for documentation on the use of temporary installations and present them to the inspector during a future inspection. Also, the inspector requested and the licensee committed to determine if any other contractors a. using temporary installations in the plant which are not easily recognizable by visual inspection of the installation.
The temporary supports used for panels C0HV-1, 2, 3. 4 were determined
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by calculation performed by MCC Powers in November of 1981 to be i
adequate and final field inspection of the installation will be I
preformed by Bechtel.
Ne s supports for instruments WMA-TT-53A/B were designed by MCC Powers in November 1981 and reinstalled by Bechtel in January 1982 and were still in the process of being inspected.
Upon inspection of support WMA-TT-53B, by the inspector, a spring nut (Unistrut hardware) was observed to be improperly seated within the Unistrut channel.
This support however has not been inspected by Bechtel for final acceptance. The concern here is that all spring nuts are not visually inspectable once the installation of the support is complete and the applicable Bechtel Quality Control Instruction has no requirement for checking spring nuts during the installation of a support using Unistrut hardware.
The licensee has committed = to require by procedure an inspection of spring nuts and to document the inspection performed.
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During the examination of calculations performed by MCC Powers to prove seismic adequacy of supports for panels C0HV-1, 2, 3, and 4, the inspector found that MCC Powers engineers had used data from the= panel seismic qualification report (Transmittal No. P64)
as design input to the MCC Powers calculation for the panel supports.
Upon verifying the design input used by MCC Powers, the inspector found that MCC Powers engineers had made changes to the above stated seismic qualification report.
The changes consist of red penciled-in changes on the calculation
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l of mounting bolt forces. The inspector determined by interview
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of MCC Powers engineering staff that the responsible engineer had made the changes because he, the MCC Powers engineer,
believes the dimensions of the C0HV panels used in the seismic qualification are in error so he recalculated forces which are higher now than the forces calculated in the seismic qualification report.
The changes made by the MCC Power engineer raise the following issues:
1)
The identity of the originator, or checker and approval of the changes was not shown on the changed pages.
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c.
IEB-79-04 - Incorrect Weights for Swing Check Valves Manufactured by Velan Engineering
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The response dated May 25, 1979 indicates that there are none of the
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described Velan swing check valves being used at WNP-2.
However, i
the Supply System did indicate that other Velan check valves were being used and that their weights have been rechecked by measurements or recalculations.
It has been determined that none of
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the valves exceed the weights indicated on the respective valve design drawings as verified in a teletype from Velan to Burns and Roe dated April 26,1979 and in a record of a telephone conversation between Burns and Roe and Velan on May 8,1979. This item is closed.
d.
IEB-79-07 - Seismic Stress Analysis of Safety Related Piping The correctness of the license response of August 8,1979 was verified by an examination of a letter from General Electric ( GEWP-2-79-948 dated May 30, 1979) and interoffice memorandum F-7 9-2582, dated July 27, 1979, with attachments from Burns and Roe. These provided the necessary supporting information to show that re-analysis of piping systems, where algebraic summation had been used, showed the systems to be within code limits for pipe stress allowable and that all supports and supplemental structures to be within current rated load capacity. This item is closed.
e.
IEB 78-14 - Determination of Buno-N Components in ASCO Solenoids In an inter-office memorandum dated January 10, 1979, the licensee stated that operations would set up a preventive maintenance program for these valves.
Establishment of this program will be examined during the review of the Operation's surveillance program.
f.
IEB-79-26 - Boron Loss from BUR Control Blades In interoffice memorandum F-81-1106 the licensee states that Operations has reviewed the subject bulletin and the related General Electric Service Information Letter and has indicated that the plant operating procedures will adequately cover the concerns addressed in the subject bulletin. This item will be examined during the review of the plant operating procedures.
g.
IEB-80-02 - Inadequate Quality Assurance for Nuclear Supplied E 91pment
It was verified by review of General Electric's-letter WPGE-2-80-015, dated March 27, 1980, as stated in the licensee's response G02-80-97, dated April 28, 1980, that the Marvin Engineering Company has not supplied the internal feedwater spragers-and thermal sleeves for the reactor pressure vessel. Therefore, no further action is required by the licensee. This item is close g-
2)
The seismic qualification report for the C0HV panels can be questioned because the MCC Powers engineer stated the dimensions used in the report were in error.
3)
The originator of the seismic qualification report had not approved the changes made by the MCC Powers engineer.
The design cantrol issue appears to be a continuing problem with Burns and Roe and the on-site contractors doing design and is discussed in detail in the inspector's examination of the Supply Systems Plant Verification presentation to Region V on February 9, 1 982.
(See pangraph 7.c.)
Seismic qualification of this equipment will Le inspected further during a future inspection.
(Followup Item L b397/82-06/01).
b.
(0 pen) (50-397/81 -03/01) Enforcement Item: Document Control Log Deficiencies During an inspection conducted 'in March 9-13, 1981, IE Inspection Report No. 50-397/81-03,1the inspector had identified five (5)
Burns and Roe drawings with each drawing having five (5) or more project engineering (directives (PED) outstanding or a PED outsta greater than three 3) months. Both cases being contrary to the requirements of Project Instruction No. WNP-2-018.'
Licensee letter number G02-81-122, dated May 28, 1981 and subsequently revised by letter number G02-81-0270, dated September 4, 1981-informed the NRC of completion dates of December 4,1981 for the Specification Control Log and April 30, 1982 for the Drawing Control Log to be in compliance with Project Instruction No. WNP-2-018.
During the current inspection, the inspector identified that five (5)
specifications (36, 58, 59, 215 and 235) were not updated as committed to by the licensee.
There is also a backlog of 1791 changes to drawings remaining on the Drawing Control Log.
It appears questionable whether or not the licensee can complete the Drawing Control Log update before the committed date of April 30, 1982.
The licensee was informed of the need to keep NRC informed should additional time be needed to achieve compliance with NRC regulations. The licensee committed to revise the Supply System's letter of September 4,1981 to show a completion date for the Specification Control Log and possibly revise the completion date for the Drawing Control Log if it appears that compliance cannot be achieved by the committed date.
(0 pen) Unresolved Item (50-397/81-03/02). Lack of Objective c.
Evidence of Independent Design Verification of Critical WNP-2 Safety Systems.
The status of the licensee program to resolve this item was reviewed with WNP-2 engineering and quality assurance management.
The inspector noted that additional information is needed to evaluate
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the nature, coverage, independent and effectiveness of all WPPSS contractors' (including Burns and Roe) programs for design verification programs in effect when safety related structures, systems and components of WNP-2 were' being designed and constructed.
WNP-2 and B&R management stated that they would provide additional information to NRC with respect to:
(1) the effectivity of the previously conducted special B&R independent design reviews with respect to their independent detection of safety related desigr. deficiencies; (2) the specific B&R minimur mandatory procedural requirements for the review and approval of both internal and vendor design documents (specifications, calculations and drawings) that were in effect throughout the entire period during which WNP-2 safety related structures, systems and components were being designed and constructed; (3) the review of the design verification procedures and practices employed by the WNP-2
"on-site' contractors prior to 1980; and (4)_ an estimate of _ the additional design assurance that would accrue if additional special independent design reviews were conducted by B&R or another qualified organization.
(Refer to paragraph 7, verification of design adequacy for details.)
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Review of Concrete Expansion Anchor Installation Program
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a.
Inspection Objectives s
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The inspector examined the licensee's actions.to_ insure adequate installation of concrete expansion anchors on safety related systems. The inspection sought to confirm that expansion anchors on safety related,_ Seismic Category 1, Quality Class 1 pipe supports met the requirements of both IE Bulletin 79-02 and other design requirements as specified by the engineer. Additionally, the inspection sought conformation that all other Seismic Category 1, Quality C1 ass 1 anchors met basic-engineering design requirements.
Burns and Roe civil engineers stated that, for WNP-2, the same basic installation and inspection requirements which were imposed by IE Bulletin 79-02 for concrete expansion anchors on safety related pipe support anchors were also imposed throughout the project.
Installation and inspection criteria defined under the'IE Bulletin 79-02 test program such as bolt preload, shell expansion, bolt spacing, thread engagement, etc. are required by the design engineer on all safety related installations.
b.
Past Deficiencies in the Expansion Anchor Program (General)
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NRC inspection reports during 1977 (50-397/77-04, 77-05, and 77-07) detailed numerous problems with the Wright, Schuchart, Harbor, Boecon Corporation, General Energy Resources, Inc's
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(WBG - Contract 215) and the previous Boecon Corporation Programs of installation and inspection of concrete expansion anchors.
The more significant problems included (1) incomplete " setting"
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-11-or expansion of shell type anchors resulting in pull-out strengths anchors (Hilti Kwik Bolts)gn, (2) installation of wedge-type less than required by desi with less than specified length thereby compromising assumed strength, and (3) installation of shell type anchors coated with low strength " low-mod" Sikadur epoxy rather than the specified high strength "high mod" Sikadur epoxy.
Subsequent sample inspections by the licensee demonstrated that the lack of adequate control in the concrete expansion anchor installation and test program was wide spread and not limited to the mechanical contractor.
NRC Inspection Report 50-397/79-12 of May-June,1979 states that as a result of defective anchor bolt installations discovered by the licensee, a program of 100% reinspection of previously installed concrete expansion anchors for all contractors including mechanical (WBG-215), electrical (Fischbach/ Lord-218), and heating and ventilation (Waldinger-216) would be implemented.
During the summer of 1979 the licensee identified several reportable deficiencies per 10 CFR 50.55(e) requirements in the area of expansion anchor bolt installation. The NRC was informed on June 4,1979 by telephone and by letter dated July 2,1979 (G02-79-120) of improper expansion of concrete anchors during installation.
From a review of the licensee's files it appears that report G02-79-120 included in it's scope several deficiencies the licensee was tracking under separate numbers; licensee deficiency number 10 - improper expansion of shell type anchors by WBG; licensee deficiency number 58
. improper expansion of Hilti " drop-in" anchors by Fischback Lord Electric Company (Contract 218), and licensee deficiency number 83 - improper expansion of shell type anchors by Waldinger (Contract 216).
Additionally, the NRC was informed by telephone on July 16, 1979 and by letter on August 7,1979 (G02-79-138) of anchor bolts installed by Waldinger (Contract 216) which had been found to have been cut short and tack welded to the back side of hanger base plates in a manner that would be found acceptable by the visual inspection and torque testing methods of examination, but, in practice, would not carry any load (Licensee Deficiency Number 62).
Thus, by the Summer of 1979 the licensee had. determined that the expansion anchor installation program at WNP-2 was uncontrolled and characterized by a-high percentage of rejectable installations which had been quality accepted.
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-12-To resolve this weakness in construction adequacy, the licensee established programs of 100% reinspection for each contractor.
These reinspection programs were implemented in the 1978/1979 time period by the various contractors. New installations were also subjected to additional inspection and verification requirements.
These programs will be addressed in subsequent paragraphs.
The inspector noted that the final reports of reportable deficiencies submitted by the licensee in 1979 discussed above were vague and of insuffic'ient detail to completely describe the deficiencies noted and that sufficient information to permit analysis and evaluation of the deficiencies and subsequent corrective action had not been included.
c.
Contract 215 Reinspection Program, Con 1pliance with IE Bulletin 79-02 The licensee established a program in April,1978 to perform a 100% reinspection of concrete expansion anchors installed by the mechanical contractor (WBG) prior to February 1978. As used here, established means that the Burns and Roe project engineers issued instructions or directives detailing the tasks to be performed. The actual date of implementation of these instructions or directives by the contractor lagged the established date as time was required to write and receive approval for implementing instructions and to provide necessary training.
The scope of the WBG 100% reinspection program as originally established was limited to anchors with design loads less than 50% of allowable strength and the reinspection criteria were directed at the known problems: A measurement of " set" or expansion of shell type anchors; verification of proper size, type, torque or preload, and adequate thread engagement; and an examination of the embedment depth for wedge type anchors.
The scope was expanded to include all anchors in December 1978.
These inspection requirements were also included in installation inspection criteria for WBG installed expansion anchors in the spring of 1978. Additionally, Burns and Roe engineering performed a test program to verify the adequacy of low strength " low mod" Sikadur epoxy for use with phillips Redhead (shell type) anchors.
Concurrent with these activities, the NRC issued IE Bulletin 79-02 on March 8,1979 with revisions on June 21, 1979 and November 30, 1979 which provided specific requirements to be implemented by the licensee to assure adequacy of pipe support base plate designs using concrete expansion anchors. Among the requirements
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-13-imposed by this bulletin were: verification that base plate flexibility was accounted for in calculating anchor loads; specific minimum factors of safety of 4 for wedge type anchors and 5 for shell type anchors; design requirements for cyclic loading; and verification by inspection that bolts were properly installed, of the specified size and type, with proper embedment depth, threaded engagement, plate bolt hole size, spacing, edge separation and with full expansion for shell type anchors.
IE Bulletin 79-02 allowed a sampling program of bolt inspection; however, sampling method guidance was provided to indicate the type of program that would be acceptable. Acceptable methods provided were (1) testing 1 bolt per plate with full plate inspection if unsatisfactory results or (2) a randomly selected statistical plan providing a 95% confidence level of less than 5% defective anchors. As the licensee had already determined that a 100% reinspection program was necessary for all contractors an inspection sample plan to meet IE Bulletin 79-02 requirements was not implemented.
Many, but significantly not all, of the IE Bulletin 79-02 inspection requirements were included in the WBG pre-February, 1978 reinspection program.
Project engineering directives were issued beginning in mid 1979 which incorporated the additional requirements in the 100% reinspection effort. By late 1979 or early 1980, a substantial part of the bulletin requirements were included in the reinspection program.
These additional inspection criteria were similarly imposed on new work during
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the same period.
It does not appear, however, that the additional inspection criteria were imposed retroactively to previously inspected work.
Reinspection to bulletin requirements was assumed for all hangers included in the program.
Additional questions concerning the adequacy of the WBG anchor
bolt installation program surfaced in November 1980 when the licensee
reported to the NRC that a number of torque wrenches used by the
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215 contractor on the reinspection and installation programs from l
February,1978 to January,1980 exceeded the permissible calibration
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tolerance (licensee Deficiency Number-98). A final report of this l
10 CFR 50.55(e) deficiency was submitted by letter on January 26, 1982 (G02-82-lll). Application of a predetermined torque to
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expansion anchors was the engineering method of assuring an anchor l
preload greater than the design load to' preclude cyclic loading effects.
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The licensee also reported to the f!RC in June 1981 that welding of stiffners to hanger baseplates by HBG had resulted in a failure in the concrete around torqued expansion anchors (Licensee Deficiency Report flumber 155). The licensee subsequently determined that this was an isolated event limited to at most two hangers.
This deficiency was identified as not' reportable under 10 CFR 50.55(e)
requirements by letter to the NRC dated January 26,1982 (G02-82-112).
On August 18, 1981 the licensee submitted letter G02-81-245 as an update to the reportable deficiency of July 2,1979 (G02-79-120)
discussed in paragraph 6.b.
This updated response is limited in scope to WBG activities and centers on reinspection to IE Bulletin 79-02 requirements.
Discussion of other contractors' efforts as identified in the sunmer of 1979 was not included.
This letter states that the reinspection of approximately 2400 hangers installed by WBG was not limited to a check of expansion, but also included items required by IE Bulletin 79-02.
The report states that as of August,1981 the reinspection of approximately 2100 hangers were complete.
In the Fall of 1981 Bechtel Power Corporation, the site construction manager assisted by the Supply System and Burns and Roe, instituted a task force to study and make recommendations on the resolution of open hanger and anchor bolt issues. The report of this task force, dated January 18,1982 (BECMCL-82-0032) again addressed the reinspection program for WBG pipe hanger anchor bolts.
The method used by the. task force was to determine the work remaining to be done on each outstanding Burns and Roe project engineering directive (PED) rather than review the extent that past work met IE Bulletin 79-02 and design requirements. The report states
"that PED-215-CS-2401 provides instructions to the contractor for evaluation, acceptance and any rework on anchors installed before February, 1978. " The report further states that "of over 2,800 pipe supports with Phillips Redheads, there are approximately 300 pipe supports remaining which require evaluation.
The inspector was unable to determine the exact number of hangers or anchor bolts installed by WBG on safety related pipe supports prior to February,1978 although a number of 2,100 to 2,800 hangers appears likely. Although only 300 hangers of this group were scheduled to be reinspected by Bechtel it was clear that the previous inspection previous program did not fully meet IE Bulletin 79-02 requirements at all times. At least 9 previous revisions have been utilized rather than the one reinspection PED listed by the task force. Specific items identified included the lack of inspection requirements for depth of shell below the concrete after initial preload torquing (pull-up), bolt hole size, and edge and center to center spacing for reinspections performed prio.- to the summer of 1979.
It was not clear that inspection of
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l-15-abandoned holes or unused anchors was incorporated into any of the reinspection program revisions although specific installation standards were established by Burns and Roe engineers.
It appeared that as many as 700 to 800 hangers may have been reinspected prior to the program changes caused by IE Bulletin 79-02.
The Bechtel task force solution to the use of uncalibrated torque wrenches by WBG was to perform a 100% retorque on all WBG anchor bolts. The inspector considers this to be an acceptable solution. The Bechtel task force also defined a method of resolving the possible interference to proper preloading of anchors caused by the widespread use of leveling nuts under baseplates. The solution proposed to determine if the leveling nut was not absorbing the applied torque appeared acceptable and will be observed in practice during future inspections. The problem of anchor pull-out caused by the welding of stiffners to hanger baseplates was not reviewed during this inspection.
d.
Other Contractor Reinspection Programs The licensee established reinspection programs for each contractor to perform a 100% reinspection of concrete, expansion anchors installed prior to the July 2,197910 CFR 50.55(e) report.
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The actual implementation of these programs to the minimum design criteria was similar to that ' discussed under paragraph 6.c. for contract 215.
Due to.the large number of project-
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engineering directives involved (hundreds) and the"possible time lag in contractor implementation, the inspector was unable to determine which anchors had or had not been inspected to minimum design criteria.
Of specific interest in'this area were contract 216 (heating and ventilation). and contract 218 (electrical).
which were mentioned in Inspection Report 50-397/79-12 as discussed in paragraph 6.b above.
e.
Burns and Roe Engineering Test Program to Meet the Requirements of IE Bulletin 79-02 The Burns and Roe engineeri.ng test program as detailed in the report " drilled-in concrete anchor tests performed at the Washington Public Power Supply System Nuclear Project 2 Site" of March 1979 and supplements 1 and 2 of August and September, 1979 respectively were reviewed for compliance with bulletin requirements. The Burns and Roe Program appeared to meet most of the bulletin requirements.
It must be noted, however, the licensee has not submitted his final report in response to the bulletin. This report is due in April,1982, and will include the baseplate flexibility analysis.
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-16-The inspector identified three areas where the licensee may not meet bulletin requirements.
First, the licensee used a minimum margin of safety of 4 for all anchor designs. The bulletin requires a margin of safety of 4 for wedge type anchors and 5 for shell type anchors. The Burns and Roe
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civil engineers stated that the necessary justification for this relaxation of minimum safety factors for shell type anchors had not been documented at the time of the inspection and was based on the opinion that there was little difference in the two types.
Second, although standards had been defined for. spacing from abandoned holes or unused anchors, there did not appear to be an engineering basis for these standards supported by a test program. Burns and Roe engineers relied on judgement in setting the criteria. The inspector noted that many abandoned holes were filled with sand and cement grout. Burns and Roe e_ngineers-stated that this grout was structural and not just cosmetic if within'an anchor stress cone (see grout problems paragraph 6.g).
Finally, specific instructions preventing the installation of expansion anchors. in grout.were not established and no requirements were established for insuring that grout used in this manner met the minimum concrete strength requirements utilized in the anchor test program. Burns and Roe engineers pointed out that the required preload was 150% of de. sign load so that any anchors installed in grout which met the preload torque without pull-out probably would not fail under load.
The inspector pointed out
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that this 'only insured a margin of safety of 1.5 rather than the
required 4 or 5 minimum.
f.
Current Installation Practices The inspector reviewed the current revisions of expansion anchor installation instructions for the electrical and instrumentation contractors for conformance with design engineering criteria.
No deficiencies were identified in current installation procedures.
g.
Inadequate Quality Control of Grout On November 14,. 1980 the NRC was informed by the licensee of a 10 CFR 50.55(e) reportable deficiency in the Contract 215 quality control program in that there was insu*ficient documentation available to support the installation of structural grout.
A.
I final report of this deficiency was sent to the NRC by letter dated February 5,1982 (G02-82-143). This report states "it has been determined that the contract 215 contractor performed
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-17-Quality Class 1 grouting, on safety related hanger baseplates, using sand cement grout without proper material traceability and quality control measures including material testing and documentation." A grout record search concluded that no usable information concerning the insallation of sand cement grout could be produced.
The licensee directed a micro-core program be established to extract small diameter cyclinders of in-place materials as test samples to prove material strength.
The program results were negative.
The in-place sand cement grout samples obtained indicated unacceptable low strength. The grout was of such poor quality that no usable core samples could be extracted.
Further investigation showed that in addition to a lack of strength, the grout installed by WBG under hanger baseplates was inadequately consolidated. Based on these results, the licensee stated that the sand cement grout placed by WBG under hanger baseplates will be replaced.
The inspector examined sand cement grout under several baseplates and found that the grout could be removed and broken up by hand.
The inspector concurred with the licensee's determination that replacement of this grout was necessary.
The inspector sought conformation that other grout installed by contract 215 was acceptable. The licensee stated that Embedco 636 grout was also installed by WBG. This expansive grout appeared to suffer from similar documentation problems. The WBG installation and inspection procedures used for grouting in the 1976-1979 period required similar documentation for both types of grout. The licensee stated that this grout appeared acceptable due to the premix packages in which it is ' supplied.
This material did not seem to be as prone to workmanship defects as sand cement grout. Burns and Roe engineers stated-that two WBG hanger baseplates with 636 grout had been micro drilled..0ne was a randomly selected baseplate which showed adequate compressive strength.
The other was a WBG baseplate 'which was ' selected because it appeared cracked or otherwise defective. This-sample showed unacceptable test results. The inspector pointed.
out that one or two samples would not constitute a statistically significant sample.
The February 5,1982 report also states that "the conditions identified... warrant (licensee) review of grout work performed under other contracts." The inspector concurred with this conclusion. This review should be of sufficient scope to encompass all structurally significant grout installed in areas h__
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-18-such as abandoned anchor holes near used anchors, patches to concrete in which expansion anchors are located, equipment mounting pads, etc.
This work will be reviewed in future inspections, h.
Conclusions with Respect to Concrete Anchcrs and Grout As noted in the proceeding paragraphs, the inspector was unable to conclude that all concrete expansion anchors within the scope of IE Bulletin 79-02 were installed substantially in accordance with bulletin requirements.
The inspector was also unable to conclude that other safety related expansion anchors were installed in accordance with engineering design requirements.
The licensee will review the implementation the anchor reinspection program to determine whicn anchors were reinspected to what criteria so that a clear presentation of remaining reinspection activities can be determined. The licensee should submit additional reports as supplements to the July 2,1979, August 7,1979, and August 18, 1981 letters. These reports should include sufficient information to permit analysis and evaluation of the deficiencies and of the corrective action taken.
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Additionally, the inspector concurs wi
_ i icensee's conclusion in the February 5,1982 report that addioonal, expanded review of past grout installation in structurally significant areas is warranted. Again, the licensee should provide supplements to this report to include the results of this review in sufficient detail to permit analysis and evaluation of the deficiencies found and of the corrective action taken.
These areas will be reviewed during future inspections.
7.
Review of Design Activities a.
Objective The objective of this area of the inspection was to determine whether design activities were being conducted in compliance with approved procedures and commitments that accurately reflect the technical and quality assurance requirements described in the facility SAR.
b.
Design Inspection at B&R'Richland Office - (WNP-2 Safe-Shutdown Capability)
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NRC Branch Technical Position Papers, sections of the WNP-2 FSAR pertaining to postulated piping failures in fluid ' systems and accident analyses, and applicable design control procedures were reviewed to determine the commitments, design bases and
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design measures employed by B&R to assure that the WNP-2 nuclear power station can be safely shutdown and be. maintained shutdown in the event of the postulated rupture of any high or moderate energy pipe outside of the reactor containment vessel.
Drawings, calculations, specifications, reports, letters, memoranda, and other documentation related to' the direct effects (pipe whip, jet impingment, etc) and the indirect effects t
(compartment temperature pressure, humidity, flooding, etc)
resulting from postulated pipe ruptures were examined to verify i
implementation of commitments.
Detailed results of this area of the inspection for the B&R Richland Office are reported in NRC inspection report 99900503/
82-01. The following significant findings were included in a discussion with B&R management on March 18, 1982:
(1) A controlled WNP-2 Project Instruction Manual contained a superseded procedure for the review and approval of calculations.
(2)
Calculations related to " Environmental Analysis Outside Containment" were not identified as " preliminary" or
" final" as required.
(3) Sources of design input / criteria were not identified nor referenced in the calculations.
(4) The group supervisor checked calculations done by his group rather then another engineer or designer as required.
(5)
Documented evidence did not exist that calculations were checked in accordance with the Engineering Standard as required.
c.
Verificaticn of_ _ Design Adequacy NRC inspection reports 50-397/81-03 and 50-397/81-17 identified that the subject of independent design verification was considered unresolved because it was not apparent that procedures have been established and implemented to assure that activities related to design verification have been carried out in a planned, controlled, and correct manner.
The reports state that the licensee committed to compare the requirements of ANSI N45.2.ll against the B&R design control procedures to identify how the provisions of ANSI N45.2.11 are being satisfied. The licensee also committed to prepare a checklist of ANSI N45.2.11 requirements, to compare these requirements with
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-20-the design verification requirements of the contracts, and to audit the contractors against aiy differences to ascertain the degree of compliance.
The licensee initiated a program in mid 1981 to execute these commitments. Review of the status of the program with WNP-2 engineering and quality assurance management indicates that:
(1) WPPSS did not compare the requirements of ANSI N45.2.ll against the B&R design control procedures to identify how the requirements are being satisfied on the basis that WNP-2 does not commit to Regulatory Guide 1.64.
However, the WPPSS review of the B&R procedures concluded that they meet the requirements of 10 CFR 50, Appendix B and ANSI N45.2.
(2) WPPSS prepared a checklist which embodied the essential elements of ANSI N45.2.11 with regard to design verification.
The checklist was used to evaluate and document the inplace
" design verification" programs of B&R, the on-site contractors, and the prepurchased equipment suppliers.
The inspector noted that:
(1) the B&R mandatory minimum review and approval requirements for B&R design documents had not been determined for the complete period during which safety related design work was performed; (2) the effectivity of the B&R special design reviews to independently detect safety significant design errors was not adequately addressed; (3) the evaluation of'
the inplace ' design verification" program / practices'of-on-site contractors was essentially based on current (post 1980) work; and (4) procedures were not available~ and therefore not reviewed, to determine the actual in-place
" design verification" programs / practices of.the-prepurchased equipment suppliers.
The WPPSS conclusion of adequacy appears to be based on a review Lof selected B&R records at the B&R home office.
The inspector found that the current B&R design control procedures do not appear to mandatorily require ~the des _ign adequacy of design documents, and changes thereto, be reviewed,
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or verified, by anyone other than the~ originator and his group supervisor.
In most cases, the decision as to who must review each document rests 'ith the originator, Group Supervisor or w
Project Administrator.
Review by other than the originator (cognizant engineer) appears to be optional. However, should a review by the originating discipline be identified as required for a specific design document, the originator'cannot perform his disciplines review specifically:
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-21-(1) Procedure WNP-2-ED-001 appears to require that a drawing, or change thereto, be reviewed by other than the originator only when another originating discipline reviewer is identified in the review block on each specific drawing or on the accompanying signature sheet by the originator (cognizant engineer).
(2) Procedure UNP-2-ED-009 appears to require that a specification, or change thereto, be reviewed by other than the originator only when another originating discipline review is identified by the Project Administrator, for new specifications, or the originator (cognizant engineer), for changes to existing specifications, for each specific specification, or change thereto.
(3)
Procedure WNP-2-ED-010 appears to permit a Group Supervisor designee or squad leader, to check work done by his group, without regard for independency, provided that he assigns himself as "another engineer or designer of adequate qualifications" to check the calculations done by a member of his group.
(4)
Procedure WNP-2-017 appears to require that PEDS incorporating design changes be design verified by the Group Supervisor, or by a qualified designee, without regard for independency.
Further, the design review requirements for original issues of design documents does not appear to be addressed in the procedu.e.
The area of adequacy of design review will continue to be followed by R:IV and R:V in their respective reviews of Burns and Roe and the Supply System.
(0 pen Item 50-397/81-03/02)
8.
Radiographs of Welds in Piping Subbassemblies Supplied by Associated Piping and Engineering Corporation (AP&E)
Radiographs of the following welds in piping subassemblies suppled by AP&E were examined to determine if there had been any mechanical enchancement of the penetrameter 4-T holes images:
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P Piece Mark No.
Weld No.
View RCIC-662-2 A
(1-2),(2-3),(0-3)
RCIC-662-9 B
(3-0)
CAC-644-1 C
(0-3),(2-3)
B (0-1)
A 2-3),(1-2)
LPCS-757-3 D
3-0),(2-3),(1-2)
C 3-0), (2-3), (1-2)
B (1-2)
RCIC-657-2 B
(1-2)
D (1-2)
LPCS-756-1 A
(0-5), (5-10), (10-15), (15-0)
B (0-4), (4-8), (8-12), (12-16), (16-0)
CAC-644-3 B
(1-2),(2-3)
D (0-1), (1-2)
E (2-3)
G (0-1)
F (2-3),(3-0)
J (3-0)
H (0-1 )
CAC-627-4 A
(2-3)
B (0-1), (2-3), (3-0)
These specific. radiographs were being examined since the required penetrameter hole image was not apparent on the duplicate radiographs retained by AP&E when examined as part of an NRC investigation of the vendor in December 1981.
The inspector was assisted by a Bechtel Level II examiner.
No enhancement of penetrameter hole images was identified.
Further, with the following exceptions, the required 2-4T hole image was visible in the penetrameters in the these radiographs:
Piece Mark No.
Weld No.
View RCIC-662-9 B
(3-0)
LPCS-757-3 C
(1-2)
CAC-627-4 B
(2-3)
CAC-627-4 B
(3-0)
The " slit" in the penetrameter was visible on these radiographs and the density appeared to be satisfactory when measured with a densitometer.
No further action was planned by the licensee pending receipt of a proposed IE Bulletin on this subject.
9.
_ Management Interview
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The inspectors met with the ' licensee's management representatives
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as noted in paragraph 1, at the conclusion of the inspection on March 5 and March 19, 1982.
The scope of the inspection and the observation and findings of the inspector were discussed.
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