ML20055B127
| ML20055B127 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/19/1982 |
| From: | Gutierrez J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Sinkin L Citizens Concerned About Nuclear Power, INC. |
| References | |
| NUDOCS 8207200383 | |
| Download: ML20055B127 (40) | |
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July 19,1982 Mr. Lanny Sinkin 838 E. Magnolia Avenue San Antonio, Texas 78212 In the Matter of Houston Lighting and Power Company, et al.
(South Texas Project, Units 1 & 2T-Docket Nos. 50-498 and 50_499
Dear Mr. Sinkin:
Enclosed for your signature is the joint motion and stipulation which we discussed by telephone. Please execute the motion and stipulation and return them to me. After all parties have signed these documents I will forward them to the Board. Should you have any questions, please do not hesitate to contact me.
Sincerely, Jay M. Gutierrez Counsel for NRC Staff DISTRIBUTION
Enclosures:
Gutierrez As Stated Reis Perlis cc: (w/ enclosures)
F.Miralgia 110 Jack R. Newman, Esq. D. Sells 116 Christenbury/Scinto Cunningham/Murray FF(2)
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NRC Docket File: PDR/LPDR i ,
, OFC :0ELDpg G :0 ELD : : :
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NAME :JGutierrez/dkw :EReis : : :
DATE :07//6/82 :07/f/82 : : :
8207200303 820719 PDR ADOCK 05000498 G PDR
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
HOUSTON LIGHTING AND POWER Docket Nos. 50-498 COMPANY, ET AL. ) 50-499 (South Texas Project, Units 1 and2)
STIPULATION Pursuant to 10 C.F.R. 5 2.753, it is hereby stipulated and agreed by and between the parties to the above captioned proceeding,' by and through their respective attorneys and representatives, that the following exhibits may be admitted into evidence, without formal proof with respect to their admissibility and authenticity, and not with respect to the truth of the matters therein stated:
Staff Exhibit No. Description Date
( 132 I&E Report 81-37 May 11, 1982 (released to PDR June 18, 1982) l
! 133 Letter, Oprea to Collins June 24, 1982 i
134 Letter, Rice to Collins June 16, 1982 I
_2 CCANP Exhibit No. Description Date 55 1976 NRC Region IV Trend Report January 4, 1977 56 1977 NRC Region IV Trend Report January 6, 1978 57 1978 NRC Region IV Trend Report February 2, 1979 This stipulation is entered and agreed to by and between the undersigned persons on behalf of the parties to this proceeding.
Respectfully submitted, Jack R. Newman, on behalf of Houston Lighting and Power Company, Project Manager of the South Texas Project, acting for itself and the other applicants Lanny Sinkin, on behalf of Citizens Concerned About Nuclear Power, Inc.
l Jay M. Gutierrez, on behalf of the NRC Staff l
l Dated at Bethesda, Maryland this I . - . - -
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
HOUSTON LIGHTING AND POWER Docket Nos. 50-498 COMPANY, ET AL. ) 50-499 (South Texas Project, Units 1 and2) )
JOINT MOTION TO RE0 PEN RECORD FOR LIMITED PURPOSE OF ADMITTING DOCUMENTS The Parties hereby jointly move this Board to reopen the record of the first phase of the hearings in the above referenced matter for the limited purpose of admitting into evidence the documents referenced in the attached stipulation under the terms stated therein. All parties waive any right they may have had to cross-examination, such as if the referenced documents were moved for admission through a sponsoring witness.
Respectfully submitted, Lanny Sinkin, on behalf of Jack R. Newman, on behalf of Citizens Concerned About Nuclear Houston Lighting and Power Company, Power, Inc. Project Manager of the South Texas Project, acting for itself and the other applicants Jay M. Gutierrez, on behalf of the NRC Staff Dated at Bethesda, Maryland this
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11 MAY M2 D:ckets: 50-498/81-37 50-499/81-37 Houston Lighting and Power Company ATTN: Mr. G. W. Oprea, Jr.
Executive Vice President P. O. Box 1700 Houston, TX 77001 Gentlemen:
This refers to the Systematic Assessment of Licensee Performance (SALP) Boa Report of the South Texas The SALP Facility, Units Board met on 1 and 2, Construction September Permit 11, 1981, to evaluate CPPR-128 and CPPR-129.
the performance of the subject facility for the period July 1, 1980, through June 30,1981. The perfomance analyses and resulting evaluation are documented These analyses and evaluation were discussed i
in the enclosed SALP Board Report. 16, 1981.
with you at your office in Houston, Texas, on October The performance of your facility was evaluated in the following functional areas:
Containment and other Safety-Related Structures; Support Systems; Licensing Activities; and Corrective Action and Reporting.
The SALP Board evaluation process consists of categorizing perfomance in e The categories which we have used to evaluate the functional area.
performance of your facility are defined in Section II of the enclosed SAL Board Report. As you are aware, the NRC has changed the policy for the conduct of the SALP program based on our experienc staff. This report is consistent with the revised policy.
Any coments which you may have concerning our evaluation of the perform of your facilityYour should be submitted to this office within 20 days of the date comments, if any, and the SALP Board Report, will both of this letter.
l appear as enclosures to the Region IV Administrator's letter which SALP Report as an NRC Report. letter will, if appropriate, state the NRC posit l
status of your safety program.
1 STAFF EXHIBIT 132
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- Houston Lighting and Power 2 g N2 Company Comments which you may submit at your option, are not subject to the clearance procedures of the Office of Management and Budget as required by the Papenvork Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, MrfsJnal stEned by-
.% C MADSEN*
G. L. Madsen, Chief Reactor Project Branch 1
Enclosure:
Appendix - NRC Report 50-498/81-37 90-490/81-37 l
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APPENDIX l -
U. S. NUCLEAR REGULATORY CON 4ISSION )
d REGION IV Systematic Assessment of Licensee Performance Report: 50-498/81-37 50-499/81-37 Dockets: 50-498 & 50-499 Category A2 Licensee: Houston Lighting and Power Company P. O. Box 1700 Houton, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 Appraisal Period: July 1, 1980-June 30, 1981 Appraisal Completisn Date: September 1, 1981 Licensee Meeting: October- 16, 1981 SALP Board: W. C. Seidle, Chief, Reactor Project Branch 2 3 W. A. Crossman, Chief, Reactor Project Section B j 0. E. Sells, NRR Project Manager H. S. Phillips, Senior Resident Inspector W. G. Hubacek, STP Transition Coordinator R. C. Stewart, Reactor Inspector J. I. Tapia, Reactor Inspector Reviewed by: e- _
W. A. Crossman, Chief Date Reactor Project Section B
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Approved by: h//)
W. C. Seidle, Chief d Odte M.
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82, j Reactor Project Branch 2 (SALP Board Chairman) i l
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l I. Introduction Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect available observations and data annually and to evaluate licensee performance utilizing these data and observations as a basis. The integrated systematic assessment is intended to be sufficient-ly diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to licensee management.
I II. Criteria The assessment of licensee performance is implemented through the use of L seven evaluation criteria. These. criteria are applied to each functional area that is applicable to the facility activities (construction, pre-operation or operation) for the categorization of licensee performance in these areas.
I One or more of the following evaluation criteria are used to assess each applicable functional area.
. 1. Management involvement in assuring quality h
- 2. Approach to resolution of technical issues from safety standpoint
[ 3. Responsiveness to NRC initiatives I 4. Enforcement history
- 5. Reporting and analysis of reportable events 6.~ Staffing (including management) l I 7. Training effectiveness and qualification I Attributes associated with the above evaluation criteria form the guidance for the SALP Board for categorization of each functional area in one of three categories. Performance categories are defined as follows
h Category 1: A combination of attributes which demonstrates achievement I of superior safety performance; i.e. , licensee management attention and
} involvement are aggressive and oriented toward nuclear safety; licensee j resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieved. Reduced NRC attention may be appropriate. .
t Categorv 2: A combination of attributes which demonstrates achievement
!{. of satisfactory safety performance; i.e., licensee management attention
) and involvement are evident and are concerned with nuclear safety; L licensee resources are adequate and are reasonably effective such that
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1 satisfactory perforsance with respect to operational safety or
. construction is being achieved. NRC attention should be maintained at normal levels.
Category 3: A combination of attributes which demonstrates achievement
[L of only minimally satisfactory safety performance; i.e., licensee management attention or involvement is acceptable and considers nuclear
- safety, but weaknesses are evident; licensee rescueces appear to be I strained or not effectively used such that minimally satisfactory i performance with respect to operational safety or construction is being
[ achieved. Both NRC and licensee attention should be increased.
e III. Summary of Results
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Functional Areas Category
- 1. Soils and Foundations . NA
- 2. Containment and other-Safety-Related 2 q
Structures.
s f 3. Piping Systems and Supports NA
- 4. Safety-Related Components NA i -
- 5. Support Systems 2
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- 6. Electrical Power Supply and NA g
Distribution
- 7. Instrumentation and Control Systems NA t
8.' Lica'nsing Activities 1
- 9. Corrective Action and Reporting 3 L
l IV. Performance Analyses The SALP Board obtained assessment data applicable to the appraisal period of July 1,1980, to June 30, 1981. The data for the South Texas Project (STP) was tabulated and analyzed and a performance analysis was developed for each of six functional areas.
] The SALP Board met on October 16, 1981, to review the performance -
j analyses and supporting data and to develop the SALP Board Report.
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Functional Area Analysis
- 1. Soils and Foundations All activities completed.
- 2. Containment and other Safety-Related Structures Limited work has been done relative to containment concrete activities. However, two noncompliances were identified: (a) failure to maintain / inspect traceability of imbeds, and'(b) failure to test for air content of grout. Limited work effort observed since the licensee lifted a self-imposed stop work order appeared to be satisfactorily performed.
One noncompliance was identified in the area of other safety-related structures: failure to assure that purchased material (inspection of Nelson stud welding to embeds) conformed to procurement
- documents. This welding was performed and inspected initially by
. Bostrom Bergen and was again inspected by Brown & Root (B&R) vendor inspectors. This item and several 50.55(e) reports have indicated a weakness in the B&R vendor surveillance program. Proper corrective action has been taken to correct this programmatic weakness.
The Board considered management control in this functional area to be of a Category 2 level.
- 3. Piping Systems and Succorts Region IV has performed very little inspection in this area for two reasons: (a) NRC efforts have been concentrated on QA programmatic areas, and (b) the volume of work activity has been low. In recent months, work has stopped in this area to allow design engineering to catch up.
The Board did not make an assessment in this functional area.
- 4. Safety-Related Comconents, Including Vessels, Internals and Pumos Work activities in this area have been very low relative to setting equipment because: (a) status of construction, and (b) sandblast activities inside Unit 1 Containment and Auxiliary Buildings.
One nonconformance was identified as a generic problem in IE .
Report 50-498/81-01; 50-499/81-01: failure to follow procedure for storage and maintenance of equipment. Corrective action to date appears to be adequate but final follow-up inspection has not been completed.
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f Due to limited work, the Board did not assess this area.
h 5. Support Systems Including HVAC, Radweste and Fire Protection 1
There was limited work in the areas of radwasta and fire protection during the assessment period. No problems were identified in these I
areas during this time.
l On May 8, 1981, HL&P notified Region IV in accordance with 10 CFR 50.55(e) of a construction deficiency concerning the
/ consideration of certain faulted condition heat loads in the design
[ of portions of the HVAC system (see item V, 1,.b, (10)). A j determination was made, based on an assessment of preliminary thermal environmental data, that certain spaces and cubicles within ~
the MEA 8 and FHB would require additional HVAC capacity. However, work relating to this item was halted due to changeover of A/Es for STP .
j The Board assessed performance in this functional area as Category 2.
i 1 6. Electrical Power Sucoly and Distribution i
No work activity has occurred in this area; however, the storage and l maintenance has been inspected and appears to be generally
)I satisfactory.
J No assessment was made in this area.
- 7. Instrumentation and Control Systems See item 6, above.
- 8. Licensing Activities Licensee activities dealing with licensing requirements have improved significantly during the reporting period. Responses to requests for information have been timely and of good quality during the reporting period. Licensee understanding of NRC requirements is l adequate.
f The Board assessed the licensee's performance in this functional 0 area to be Category 1.
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- 9. Corrective Actions and Recorting
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The constructor (B&R) continues to experience difficulty relative to j corrective action. It also appears that the root cause of the problem associated with NRC and licensee identified deficiencies is i
that the deficiencies are not effectively corrected and are not
] corrected in a timely manner.
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i Some improvement has been noted, but the constructor has not been f able to properly address the issue because of the extreme demands y placed on all licensee and contractor organizations by the NRC Show i Cause. Responsa effort to the NRC Show Cause has resulted in l
extensive reexamination / repair programs, special technical and QA reviews, organizational restructuring, numerous personnel changes, and rapid turnover of personnel including key management positions.
In all fairness, the performance of the constructor site organization should be evaluated during more normal conditions.
Senior licensee and constructor management must continue to be inticately involved with the cor ective action process to assure i that this area is improved.
Licensee reporting of construction oeficiencies in accordance with 10 CFR 50.55(e) requirements has been satisfactory in all respects.
i The Board assessed licensee performance in this functional area to be Category 3.
I 10. Conclusion j The Board based their overall assessment on review of the QA program corrective action and on observing limited work activity caused by L the IE Investigation Report 50-498/79-19; 50-499/79-19, Show Cause
[ and Stop Work Orders imposed on Brown & Root, Inc. , the prime contractor, by the licensee. The rating was most heavily influenced
[ by B&R's continued inability to' correct the root causes of problems
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R and take corrective action in a timely manner. The QA program's I success is largely dependent upon the correction of the cause of deficiencies.
r Although Houston Lighting and Power Company (HL&P) has taken l affirmative steps and actions in the area described aDove, the implementation of corrective action measures and procedures is still considered a weak area. Therefore, the overall rating for licensee performance is determined to be Category 3, because of HL&P's inability to compel a significant improvement in B&R's performance in this area.
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- 11. Board's Recommendations
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The Board recommended augmented inspection of the South Texas D Project through the transition phase of construction and into restart of construction until performance demonstrates that normal
] inspection activities may be resumed.
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V. Supporting Data and Summaries l
l 1. Reports Data
- a. LER Numbers Reviewed (not applicable)
- b. Construction Deficiency Reports The licensee's system for reporting construction deficiencies j is located in the Houston offices. Deficiencies identified t
onsite are forwarded to the Incident Review Conunittee (IRC) for evaluation. IE Inspection Report 50-498/81-07; 50-499/81-07 documented a review of this system which included: (1) reviewing licensee written reports for 1980, and (2) reviewing 58 IRC evaluations from April 26, 1977, to July 3, 1980.
Eleven reports from July 1,1980, to June 30, 1981, were g reviewed and evaluated. These deficiencies are described below:
(1) Design of Auxiliary Feedwater Pump (All environmental facters not considered in design.)
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(2) Breakdown in QA Program Relative to Application of Paint to Steel and Concrete Surfaces Except for Liner Plate j (3) Reactor Containment Building Structural Steel Beams Loading f (4) Unacceptable Surface Condition of Weld in Main Steam Piping and Secondary Shield Wall Whip Restraints (5) Cooling of Primary Shield Wall Penetration Insufficient Air Flow Between Reactor Coolant Hozzle and Seal Plate (6) Inadequate Cable Tray Hanger Design (7) Hilti Anchor Bolts Design Strength Inadequate (8) American Bridge Structural Steel Welds Deficiencies (9) Non-Approved Hilti Revised QA Manual
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1 (10) Faulted Condition Heat Loads in Design of Portions of the f' HVAC System (11) Computer Program Verification -
A trend was noted relative to the deficiencies reported; that is, 7 of 11 were design problems. As a result of this trend and other information, a special NRC inspection of the
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'l design engineering organization was requested on May 27, 1981.
$ That insoection and review is still in progress and final results are not available.
- c. Part 21 Reports The licensee reported two 50.55(e) construction deficiencies as a result of two Part 21 reports which were reported to the licensee. These items are as follows:
(1) CONSIP Pump Shaft Failure
! (2) Steam Generator Water Level Measurement System Error i 2. Licensee Activities The licensee's construction activities have been low during the subject period because of the NRC Show Cause Order and Stop Work Orders imposed by the licensee.
- 3. Inspection Activities 4
A special team was assigned to follow up on the IE Investigatjan 79-19 and the Show Cause Order. This effort continued during the entire reporting period and involved approximately 1318 inspector-hours. An insignificant number of inspector-hours was i devoted to the routine inspection program because of follow-up and reactive inspection.
- 4. Investication and Allegations Review L . Twelve investigations were conducted during the subject period which I involved 756 inspector-hours. These investigations are summarized below:
Subject Results b a. Three allegations relative to Allegations were '~' confirmed.
(1) painting records, (2) weld rod oven power loss, (3) RCS-2 i settlement. *
- b. Seven allegations relative to Specification, improper coating;
- *I (1) improper specification improper coating records at
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contractor were confirmed.
revision; (2) improper appli-
! cation of coatings, (3) Remainder were not confirmed.
j design engineers not l
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i Subject Results
, qualified, (4) QC coating records falsified, (5) coat-j ing records not authentic, (6) American Bridge coating records incomplete, (7) improper coating repair.
- c. Two allegations relative to The first allegation was (1) B&R foreman intimidating confirmed; however, morale employees, (2) B&R management and personnel problems were took no action on electrical turned over to HL&P 5
department problems, management.
- d. One allegation relative to Allegation confirmed.
site personnel knowing .
that an NRC investigation was to occur.
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- e. Eleven allegations relative All allegations confirmed to (1) B&R intimidation of except unqualified personnel employees, (2) inadequate and concrete form shift.
inspection of materials leaving warehouse, (3) electrical personnel not qualified, (4) concrete form snifted, (5) HL&P/B&R
( forewarned of NRC inspection,
( (6) FREA procedure improper, t (7) B&R performing work that should not have been performed, (8) low morale, (9) termination shack calibration practices improper, (10) B&R did not advise employees of results of employee survey, (11) procurement of electrical supplies improper.
f f. One allegation relative to Allegation not confirmed.
pipe sleeve weld defects.
- g. Four allegations relative to A11egntion (4) was confirmed ,
(1) electrical shop records / but itam was not safety-L calibration, (2) storage of related.
j safety-related piping in lay down area "M", (3) storage of 3
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] Subject Resuits safety-related piping in fab shop area, (4) 8&R piping isometric drawings differ from
- specification sheets.
1 h. Three allegations relative to Allegation (2) was confirmed
, (1) B&R foreman fired because and (3) had "some merit."
he resisted production pressuras, (2) B&R rehired j personnel formerly fired because of conditions identified in IE Report 79-19, J (3) Cadweld records inadequate and falsified.
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- i. One allegation relative to Allegation was not confirmed.
]:! drug use at STP must affect quality of construction.
- j. Five allegations relative to Allegations were not confirmed.
(1) construction deficiencies not properly reported, (2) clearly promoted to project quality engineer not qualified, (3) B&R auditor at STP not qualified, (4) management intimidated an employee, (5) B&R engineer's experience L inadequate for position to which he was to be promoted.
- k. Four allegations relative to Allegations (1) and (2) were (1) designers of STP piping not confirmed, while (3) was systems are not competent, turned over to Region IV (2) supervisors signing / Vendor Inspection Branch.
I approving drawings not
- i competent, (3) Nuclear Power Service, Inc. , is worst contractor onsite, 1: (4) B&R stress analysis of f piping system questioned.
e 1. Two allegations relative to Allegations were confirmed.
(1) permanent plant equipment
, not inspected and records falsified to show inspection i
results, (2) millwright l foreman not qualified.
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! 5. Escalated Enforcement Actions
- a. Civil Penalties, and
- b. Orders The NRC imposed a $100,000 civil penalty and issued a Show Cause Order to the licensee on April 30, 1980. The licensee paid the civil penalty and provided a complex and detailed
[ response on July 28, 1980. In accordance with the Order, on f August 19, 1980, a public meeting was held between NRC and I licensee senior management to discuss the subject response.
I Senior representatives from B&R also attended. These i proceedings were documented and placed in the Public Document Room.
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As a result of this meeting, HL&P summarized all commitments p made in the written response, commitments made between NRC and licensee management, and commitments made at the public meeting in HL&P letter (ST-HL-AE 533) dated September 18, 1980.
j Parties to intervene requested that all construction work be stopped but this request was denied. However, the Commission did decide to have accelerated hearings on the QA portion for the operating license to detemine the licensee management's character and competence. These hearings started on May 12, 1981, in Bay City, Texas, and are expected to extend into late fall 1981.
- c. Immediate Action Letters
. Nine imediate action letters were issued relative to confirming stop work actions imposed by the licensee. The following is a summary.
(1) Issued July 17, 1980, confirming licensee self-imposed Stop Work Order to check adequacy of controls for AWS welder qualifications and requalifications.
(2) Issued October 3, 1980, confirming licensee's commitments
! regarding re examination, repair, and restart of AWS l welding.
L (3) Issued October 22, 1980, confirming licensee's commitments ,
for acditional AWS safety-related welding.
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l' I (4) Issued November 21, 1980, confiming licensee's commitments regarding initiating ASME welding activities.
(5) Issued January 5,1981, confiming licensee's commitments regarding the ASME safety-related welding 10-Week Work Plan and resumption of safety-related AWS welding.
(6) Issued January 13, 1981, confiming licensee's commitments regarding initiating complex concrete work activities.
(7) Issued February 19, 1981, concerning substitution of certain ASME welding identified in the ASME safety-related welding 10-Week Work Plan.
(8) Issued March 31, 1981, confirming licensee's commitments regarding further limited ASME safety-related welding as
[ outlined in licensee's 12-Week Work Plan.
(9) Issued April 16, 1981, confiming licensee's commitments j regarding expanding complex concrete work activities.
- 6. Management Conferences Held During Acoraisal Period I
The following were management meetings held during the SALP g reporting period:
I a. At the request of the licensee, a management meeting was held l on June 17, 1980, to discuss actions being developed regarding i Show Cause Order items.
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. b. At the request of the licensee, a management meeting was held to discuss actions being taken regarding Show Cause Order items related to Special Investigation 79-19.
- c. November 18, 1980, to discuss status of outstanding Show Cause Order items and restart of work.
- d. March 23, 1981, to discuss restart to ASME welding and current l1 status of Show Cause Order commitments.
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' i June 24, 1982 ST-HL-AE-841 {
F11e Number G't.12 l 4
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Mr. John T. Collins ,
kenional Administrator. Region IV l Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 1000 m%) ,
Arlingtor., TX 76012
Dear Mr. Collins:
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,E South Texas Project
-- E Units 1 A 2 ^
Docket Nos. STN 50-498, STN 50-499 ,
Systematic Assessment of ticense Perfnnnance (SitLP)
Board Report f,o_r the south Texas Pro.iect i
i We have reviewed the 5Atis Hevort for the STP dated May 11. 1982. Tne report, which covers the period from July 1, 19tE to June 30, 19P,1, states that thE overall ratinc '%a5 most heavily influenr.ed by BF.R's continued I inability to enrrect the root cause of problems and take corrective action in a timely mnner.'- We understand that the SALP Board's conccen centered prirl,arily on sont audit deficiency reports ( ADR's') . Currective Action Reu/ests (CAR's) and unresolved items that were outstanding during the review period, l
' cnd the period of time rendired to resolve anci implerrent the necessary cor-r rer.tive actions. We believe that actions taken hy HLM demonstrate that we l have put in place a project management syster. that assures our contractors effectively implement corrective action in a timely manner. j i
h the reunrt notes, the period fro' July 3.108", tc slun#- 30; 19?!,
w.a nr* n narr.7.1 r.eeioc 61 the t '8 'c et unh& t:. trw Fr.nt (6 'r Ordei re-sultec in extensive reexen.srioLion an:1 repair, speci61 tcf.hnical and 0A l
' reviews, organizatinani restructurino and chances in personnel, including some key managenent positions. As a result. HL&P. focused on accelerating the implementation of an improved overall program that provided the basic features necessary to achieve successful resolution of specific issues such r as ADR's and CAR's. By the end of the SALP review ocriod nany improvenients I had been niade in the OA program.
After implementing the program improvements liL&P took aggressive action to assure that BAR promptly implemented required corrective actions. For I
' example, at the beginning of 1981 there were a large number of outstanding STAFF EXHIBIT 133
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II.in Itan Lighting 1: Petut;t (Almpatn June 24, 1982 1 i
$1-HL-AE-841 a-File Number G3.12 l .
i Page 7 ADR's and CAR's, however, by the time of the SA1.P Board meeting with HL AD n.;:rugen.cnt in Octoter, there had been a significant reduction in the number nf outstandinu ADP.'s and CAR s.
By the end of 1981 BAR correctis actions were essentially up to date. ,
To assure that its contractors continue to implement correct.ive r.ction in a tinely manner, HL&P procedures have been revised tn reouire that when-ever a response to an ADR or CAR is overdue for an excessive period the matter will automatically be escalated to successively higher levels of manecement in the delinquent organizations, and In HLAP.
As a result of the change in contractors on the Project, we anticipate a more responsive attitude toward corrective action reauirements in the future, both Bechtel and Ebasco have brought totthe Pro.itct organizations a high level of successful experience in nuclearidesign and constructicn which
-was prrciously lacking in the contractor at STP.: In addition to the. w-pro.ed level of nuclear experience among key project personnel, both orger:izations are implementing procedures that have proven successful on other nuclear projects. Both Bechtel and Ebasco procedures reuuire that overdue currective action items be ercalated to biqher manacement. HLF.P hai directed liecntel to assuec that apDroprietc action is takm. on the fer; rer.aining item.s thr,t still require resolution ur imDiementation.
In sur::, we nor cc that the "0/. prooram's success is largely dWpendent Upor. the correction of the cause of deficiencies " and we believe th=t our actions represent hipni'icent steDs toward clitrination of thc root cau3es of past problems.
Ver rul .ypurs,
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STAFF EXHIBIT i34 d
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Brown & Root,Inc. ] :'
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j Mr . J ohr. T . Collins f '.
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Deputy Director ' .
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-- b U. S. Nuclear Regulatory -
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Commiecion f 611 Ryan FlaEn Drive t h Arlington, Texat '(6011 , .
RE: South Texas Project, Unite 1 and ? l Docket Nos .,_50 ,8 28.2. 50 499 6 l4 d'
Dear Mr. Co311ns:
1 We have received and reviewed therSystematic Ter the Assess- above ment of Licensee Performance ("SALP") NeDort facility, issued under cover letter datedThe May 11, page 1982,of l[l first frorr. G . I.. Madsen to G. W. Oprea, Jr. of the fec111ty l
the Meport indicates that the apprainn3 The Report and cover I
was corepicted on September 1,1981. i letier SisLPfurther hosrd with indicate that there Mr. Oprea snd otherwas reprcuentatives a meetinP. of the of i
("HL&P") on j liceneen Houston Lighting & l'ower Company to discuss a preliminary draft of the l
October 16, 1981, and the performance ana3ysis and evaluation ~
[
SALP F.cport ,
conte $ned in it.
]
Brown & Moot, Inc. ("B&R") was not invited by HL&P to 1 tne October 16, 1981, meeting and had no cpnnrtunity ?.o c:n r.er,t or: the dra fi Fl.M %ap-r- n' po rti ^. ve: r r.t #- 5 * .-N.
vion G , ht.
cther way in the preparst'.or l'armeraphsof tne final10 in the SALF 9 and heport. Ikvertheless
[
Eeport draw a number of conclusions about B&R's clieged inability to correct action in a timely manner.
As you know, on September 16, 1981, HL&P disn:iss'ed
( B&R from On1te architect-engineer December 16, 1981, and construction canagerHLEP filed a civil suit ag l role.
BER in the District Court .for Matagorda County, Texas.
The nuit alleges, among other things, that B&R treach'ed j
f its contractual obligations to NL&P by defective perform-j ance in the engineering and construction of the 3.:uthbetween Texku q
Froj ect . As the above dates indicate,'the meetin: I the SALP Board and Mr. Oprea and other HL&P officials to discuss the draft SALP Report took piece after HI.&P had f
dismissed B&R and, presumably, wh3]e HL&P was prepari.ng 890 civil action againct B&M. .
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. 4 Because of this pending litigation, I shall not here . g.
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oirberate on our disagreements with the observations in C" , !!
p Paragrap?p9 and 10 about BAR's performance. T do , howeve:', ,"
sl Wish to note our understanding that your inspectnra doinot -
normully seek to determine the nature of the interactions d hetweer. NRC licensees such as ML&F und their contractors f or agentt, euch as R&E. This may have givon rise to the i
t proo.:. ems referenced in Paragrapne 9 and 10. While those .
'Ij interactionu may be of little interect to the Nit 0 for att regulatory purposes, in our view, those interactions ! ll necessarily affected the nature and timing of B&R's ecprect- '!
ive actions, lt is unfortunate, therefore, thst HL&P did not elect to invite D&R to the October 16, 1983, inenting to h'!
discuss your draft Report. B&R was effectively precluded ll thereby from discussing with you the many difficultice :we oncountered in denij ng with HI.&P's Project Management Team, f[
as well as ELIiP's management, and from otherwise commenting on the draft Iteport. This could possibly have svo$ded the Elj unfortunate impliention of the obuervations in t,he SALP 0 Iteport regarding B&F.. fl i
Very tru yours, .
t
.j ec4 Wil lada 4 Rice j{
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cc: G. W. Oprea '
y J. H. Goldberc i N,
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- c 8 f i L Cf I?.58 t *1 tt*. a'.t E f.8 0 Rett.1E NT l'.E clCN av Eli PY A'. PL A* A DatVE. susTE 1000 ARLINcToN. TE A AS 76312 January 4, 1977 V. /.. Ctessnan, Chief, Projects Section Tr.IND A'*Al*? SIS - 1976 Tne start of a new year is a good time to step back and take a look at the perfor:ance of our assigned licensees during the past year.
If, in our evaluatioc, we detect negative trends, then we should pro =ptly arrange through regional supervision to discuss these findings with corporate =anagement. ,
Please re:iuest ycur Tscilities Inspectors to conduct a trend analysis
~
6f the perfor ance of each of their assigned " active" licensees during calendar year 1976. Specific areas to be considered should include:
I
- Nunber and repetitiveness of Construction Deficiency Reports.
- - Inforce=ent history, e.g. , nu=ber and repetitiveness of non-co=pliance ite=s.
- Responsiveness of licensee to enforcement action.
- Nc=her of outstanding unresolved ite=s - timeliness of resolution.
-- Corporate managenent involvement in regulatory matters.
- Effectiveness of QA/QC programs.
l l - Ar.y other trends indicative of poor perfor-=~ce.
Please forward your written evaluations to me be COE January 26, 1977.
! W. C. SeidleT Chief Reactor Construction and Engineering Support Branch
! cc: R. E. Rail W. E. Vetter l
CCANP EXHIBIT 55
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I TREND ANALYSIS 1976 REACTOR CONSTRUCTION BRANCH i
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- ...* January 14, 1977 l
M D!O.%'.J.7: TOR: W. G. Hubacek
- R. G. Taylor R. C. Stewart I C. R. Oberg g i
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, TRO.M: U. A. Crossr.an, Chief, Projects Section SUEJECT: TREND ANALYSIS - 1976
[ Enclosed is a ce=o from Bill Seidle concerning licensee performance trend analysis. To answer his questions please provide the following CY 76 h infor=ation.
t i a. Nu=ber and Recetiveness of Construction Deficienev Reports i.
k . (I have this information already)
- b. Enforcement History l
Tor each facility list:
I (1) Inspection Report Nu= hex l (2) Dates of Inspection (3) Number of Violation (4) Number of Infractions P
(5) Nu=ber of Deficiencies (6) Number of Deviations f' (7) Mandays involved (for that inspection)
(9) Re= arks (indicate if repeat fro = 1976 and 1975)
, (6') Nu=ber of outstanding unresolved items
) c. Responsiveness of Licensee to Enforcement Action (1) 1s licensee on time with answer to our letter?
(2) Are answers adequate? Do we have to go back for more information?
4 (3) Is corrective action done promptly?
j (4) Are any inadequate answers our fault?
- ,' (5) Is the licensee responsive in your op.6fon? Why?
i . - _ . . . . .
- 1 1 _ . _ __ ._ _ _ - _ _
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- d. W :ber of 1*nresolved Items - Titeliness Resolution I
(1) :;u=Sers are given in b.(9) above.
(2) Are unresolved items cleared rapidly? ,
(3) Average time to clear.
(4) Are numbers / inspection on the increase? Vny?
- e. Co norate Management involve =ent in ?erulation Matters (1) Sufficient manasecent representation of exits?
(2) Attitude receptive?
(3) Signature on licensee letters appropriate level?
(4) Is management involved? (indicate basis for answer)
! f. Effeetiveness of QA/QC Program This is a vary subjective matter. I desire your own opinion and what you brw your opinion on. If too early in construction phase to state, indicate this. Also indicate what you believe we can do
.to have them ,'.mpro've their program.
- g. Anv Other Trends Indicative of Poor Performance 1
List and discuss any other indications that may point out poor /
good performance.
j As a last item, give ne your . general reco=mendation on advisability of holding a periodic management meeting with all licensees to discuss past performance and identify possible problems for the licensee- to avoid.
As indicated in the enclosure, this is to be your assessment of your "ac'tive" facilities. Please have your information to me by COB on I
January 25, 1977.
1 MI_m W. A. Crossman, Chief Projects Section 3.
A I
Enclosure:
l As stated cc: W. C. Seidle b l s
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- - - - .-...-.n . . . . - - . . -.
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TF.E C AMLYSIS SOUTH TEXAS, UNITS 1 & 2
- b. Enforcement History See attachment
- c. Responsiveness of Licensee to Enforcement Matters (1) Yes (2) On the basis of one completed correspondence cycle - yes they arc adequate.
(3) Yes (4) Not applicable
, (5) Yes - licensee personnel, while well qualified, are somewhat in-H experienced at QA and have expressed appreciation for the occasional suggestion on how to head off problems.
- d. Number of Unresolved Items - Timeliness Resolution (1) In b above
- (2) Yes
.1 (3) General one inspection cycle.
(4) No
- e. Corporate Management Involvement (1) Both licensee and general contractor site management and usually the licensee's home office project QA manager attend the exits.
') (2) Very
( (3) Executive Vice President appears adequate.
(4) I believe licensee management is very involved. The impression is that the executive VP is of the opinion that their program should be
'I good enough that we will have n_o, negative findings. 4
- f. Effectiveness of QA/0C Program
!l It appears that the licensee has gathered a group of technically sound, l
agressive people to maintain surveillance over the general contractor who
',( ,
has line level QA/QC responsibility. The general contractor (Brown & Root) 7
- .._. __ _..m ..... . _ _ . _ _ _ - . _ . _ .
. QA/QC appears to have an acequate procrar but has some reluctance 3
to exercise its authority. Few strong positions are taken unless
- the licensee provokes action.
< Programmatically both the licensee and Brown & Root are quite adequate.
The only real solution (s) are:
(1) The licensee take over full QA/QC responsibility with B&R having none, or (2) Replace B&R QA/QC site management and perhaps some home office management with personnel with more intestinal fortitude.
- g. Any Other Trends 1
As a further point on f above, it was the licensee who provoked B&R QA into taking action against PDM. B&R supported the December 30, 1976, Stop Work Order with a very weak group of descrepancies uncovered by an audit performed that day, but had been maintaining full time surveillance over PDM for six weeks. It has always been axi.omatic that it is far easier to be agressive and firm with subcontractors than with your com-
! panies' construction forces for obvious reasons such as continued employ-1 ment. Here we have the situation where B&R QA could not bring it upon I themselves to take effective action with a subcontractor. What is probable when B&R begins the nore difficult and important work involving piping and electrical systems? I think we wait and see.
1 I see no reason for periodic senior level management meetings. Manage-ment meetings should be reserved for actual need so as to keep high
, visibility status.
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A 8 . ' *. : * * . 117.3.! it: 1 January 6,197E MEMOPR;DUM F0;.: W. G. Hubacek R. G. Taylor R. C. Stewart C. R. Doerg FROM.: W. A. Crossman, Chief, Projects Section SU5 JECT: TREND ANALYSIS - 1977 Flease perfern a trend analysis of the performance of each of your assigned "a:tive" licar. sees fer the calendar year 1977. In cases where responsibility for licenseas is being reassigned, the inspector who was responsible for the licensee ir. :aiendar year 1977 will prepare the analysis. Your analysis i
should incle:e tne followin5 information:
) a. Number and Repetiveness of Construction Deficiency Reports t
- b. Enforcs +nt History For each facility list:
(1) Inspe: tion Report tiumber (2) Da es of Inspection (3) Nun:er of Violations (t) Nerrer of Infractions (5) nc :er of Deficiencies (6) Nu .rer of Deviations (7) Mandays involved (for that inspection)
(8) Re arks (indicate if repeat from 1977 and 1976)
(9) N; rer cf unresolved ite s
- c. Resoonsivenest of Licensee to Enforcenent Action
- (1) Is licensee on time with answer to our letter?
(2) Are answers adequate? Do we have to go back for more information? ,
(3 Are any inadequate answers our fault?
(4 Is corrective action done promptly?
i (5 Is the licensee responsive?
I
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1 f CCANP EXHIBIT 56
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- c. Unresob.e: I ens J
a (1) Are unresolvec items cleared rapidly?
(2) Are numbers / inspection or, the increase? Why?
(3) t,crber of unresolved items escalated to enforcerent items.
1
- e. Corocrate Manageren: Involve-ent in P.e;ulation Matters (1) Sufficient canagement representation at exit ir.terviews?
(2) At-itude rece:-ive?
(3) Signature or, licensee letters appropriate level?
(4) Is ran65ement involved? (Indicate basis for ar.swer) l f. Effectiveness of OA/0: Program I This is a very subjective matter. I desire your own opinion and basis for yeu- opinion. If toc early in construction phase to state, indicate this. Also indicate what you believe we can do to have them improve their prograr.. This information should not be included in the documented analysis, but you should be prepared to discuss it with Mr. Seidle.
- g. Anv Other Trends Indicative of Poor Performance List and discuss any other indications that may point out poor /cood pe rf o rcance.
Please have your inforcatier. to te by CC3 on January 31,197E.
==:-
W. A. Crossman, Chief Projects Section cc: L' . C . E s i di s i
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- MEMORANDUM FOL.
- V. A. Crossr.an, Chief, Projects Section FROM: R. G. Taylor, Reactor Inspector, Projects Section
Subject:
TREND ANALYSIS - 1977 SOUTH TEXAS PROJECT, UNITS 1 & 2 5,
DN 50-498 & 499 1 The following information is provided in response to ycur memorandum, same subject, dated January 6,1977.
j a. Number and Repetiveness of Construction Deficiency Reports (1) Number = 1 (2) Repetiveness = 0 i
- b. Enforcement History Please see attached summary.
- c. Responsiveness of Licensee to Enforcement Action
\
l (1) Licensee has been on time with responses.
j (2) Two of five responses were considered inadequate.
, (3) I don't believe that we were at fault for the licensee's inadequacy.
(4) The licensee is very prompt with his corrective action.
(5) The licensee is responsive to our actions.
- d. Unresolved Items (1) Unresolved items are generally cleared very quickly.
(2) There is no particular trend apparent.
(3) None of the unresolved items have been escalated.
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- e. Corporate Management Involvement in Regulation Matters (1) The licensee and his general contractor have been very
- adequately represented at exit meetings.
(2) The licensee management's attitude is very good.
(3) The licensee's executive vice president is signatary on letters to us.
(4) The licensee's management gives a picture of close involvement as based on discussions with subordinate personnel and review of notes attached to audit reports and letters reviewed during inspections.
- f. Effectiveness of 0A/0C Program The licensee appears to be well motivated. Such problems as there are have been discussed with you and Mr. Seidle.
- g. Other Trends Indicative of Poor Performance j None.
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SOUTH TEXA5 FRN ECT, UNIT 1 D/N 50-495 i
Report Dates y_ I_ D D_ M/D U Remarks
, 77-01 1/03-06/77 0 0 0 0 7.875 1
.375 Environmental 77-02 1/27-28/77 0 0 0 0 0 Inspection 77-03 2/02-03/77 0 0 0 0 2.5 0 Investigation s
- 77-04 2/15 & 3/1-4 0 1 0 0 6.875 1 I 77-05 3/27-31/77 0 2 0 0 7.875 1 77-06 4/26-29/77 0 0 1 1 4.75 1 77-07 6/20-22/77 0 0 0 0 4.25 -
1 i
- 77-08 7/06-08/77 0 0 0 0 3.5 0 Investigation
! 77-09 9/27-30/77 0 0 0 0 6.375 0
- 77-10 10/25-28/77 0 0 0 0 2.625 1 t'
i 77-11 11/08-11/77 0 0 0 0 6. 5 1 77-12 11/29-12/1/77 0 0 1 1 1.5 0 t
77-13 12/19-21/77 0 0 0 0 2. 0 0
- 77-14 12/15-16/77 0 0 0 0 1.5 0 Investigation e TOTALS 0 3 2 2 58.5 7 I
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SCJin TE).A! F~.2 JECT, Ut;;T 2 D/t. 50-499 E
< Enforcement
-y Report Dates V, I D q M/D U, Remarks y 77-01 1/03-06/77 0 0 0 0 .125 0 77-02 1/27-28/77 0 0 0 0 .375 0 Environmental Inspection 77-03 1/26-29/77 0 0 1 0 1.25 0 77-04 9/27-30/77 0 1 0 0 2.875 0 77-05 10/25-28/77 0 0 0 0 .25 1 0 77-06 0 3.0 11/08-11/77 0 0 0 0 77-07 11/29-12/1/77 0 0 1* 1* 1.375 , O
- shared with
- Unit 1 77-08 12/19-21/77 0 0 0 0 3.125 0 77-09 12/15-16/77 0 0 0 0 1.5 0 Investigation
- TOTALS 0 1 2 1 13.875 1 I
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i February 2,1975 MDl0RANDLE FDP.: W. G. Hubacel R. C. Stewart R. G. Taylor ,
C. R. Oberg W. A. Crossman, Chief. Projects Section FRCP.:
SUBJECT:
TREO ANALYSIS - 1978 flease perform a trend analysts of the performance efesch of your '
asstyned %ctive'41consees for the calendar. year'5978. In samesesassigned avhere avsponsibility for 31censees ts As who ses responsible forh 4iconsee Sims andarpar 1978 erill gre-pare the analysis. 4our analysis sho018 4acludethe Tollowing infor-mation: ..,
- m. " Dauber and Rapetiveness af htructlen 3eficiency toports l A. . Xnfortsment ettstory for each f acility list:
Ii Inspection aaport eussber .
j (l1)2)
Dates of Inspection .
- 3) -tuseer af Wtolations (1 manbar af Infnactions l '54)) -
f 6!) $sber.af Seficiencies 4hamberof Sevlations '
-i 71
) 'Sandays involved (for that inspection)Samarts (indica M -hbar ef.asnnesolved 1taas c.
aesponsiveness of Licensee to Enforcement actior.
Jl I
-12) (1) .Aru1s 11causee answers adequate?on time trith Do answer are havetotosur go letter?
back for more info :.
--mation?
S') .Are arg Snadequate answers ourfault? -
4
.; (b .ils corrective eetton done Srsaptly? 3
- 5)Y'Is the 11consee responsive?
/ I 4tIV CCANP EXHIBIT 57 5
,' gnkun.ff=Nssman7mh S E b* YM N
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- c. ' enresolvet 1tecs f 1) Are unresolva:! itar.s cleared rapidly?
l 2) Are mmbers/ inspection on the increase? Eiy?
., i 3) humber of unresolved itams escalated to enforcement itar.s.
.]i 3
- a. Corporate Management Involvement in Regulation Matters
.1 :
.j l (1 Sufficient management representation at exit interviews?
Attitude receptive?
l (2 l (3 Signature on licensee letters appropriate level?
. (4 Is management involved? (Indicate basis for answer) l T. Iffactiveness of OA/QC Prograr.
\
- Thisis e eerymtbjective matter. 3 desire your own opinion and
! &asts Tor.youropinion. Of too early in construction phase to
- state,1ndicate this. Riso indicate what you believe se can do
- e have ther derove their program. This informe.tton should not he included to the documented analysis, but you should be prepared to discass 1tarith W. Seidle.
- 4 @ Sther Trends Indicative of foor Performance 4.1st anddiscuss erny ether indications that any point out poor /pood i
- .perfpruance.
I 11 ease have your1nformation to me by COB an'Tabruary 28, 1979.
1 't
's t w 's,cre il b %. A- W it. A. Crossman, Chief frsjects Section
. -.sec: Af.iiC.'Beidle
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Oc ocer 15, 197E 1
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.j MEM3 RAND'JMFOR:t W. A. Cross.an, Cnief. Prcjects Section i
FR0!': R. C. Stewar., Reactor Inspector, Projects Sectier.
SU5JE- ; TREN; ANALYS!! - 197E The attacnec infomation is previoed you in response te your memorandu ., same subject, cate: FeDruary 2, 1979. The information, preparec Dy each cf the assignec project inspectors, include only those facilities that were in an active cons ruction status curing CY 197E. -
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1 R. C. Stew ,, Reactor Inspector Projects Sectior.
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O. w Texas Project L .t u 1 & 2, DN 50 49E; 50-49E-TRE C ANALYSIS - 1978 .
d -
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- a. Number and Recetitiveness of Construction Deficiency Reports l Seven items were reported as potential construction deficiencies of which four were determined to be reportable in the context of 50.55(e).
Two of the items (voids in Lift 15 of Unit 1 containment and voids in the slab under Unit 2 spent fuel pool) were repetitive.
- b. Enforcement History
- (See attached sheet)
- c. Responsiveness of Licensee to Enforcement Action 1
J (1) The licensee was timely in all responses except to our letter of November 15, 1978, which transmitted report No. 78-16. The response to this letter was dated January 8,1978. This late response was aoparently due to simultaneous reassignment of the Project QA Supervisor and the Site QA Supervisor at that time which caused a temporary discontinuity in their tracking system. ,
(2) Answers were generally adequate except the initial response to report No. 78-16. Items failed to adequately address corrective actions to preclude recurrence. A subsequent response, which we requested, was adequate.
(3) Inadequate answers were not our fault. The licensee attributed the inadequacy of their response to report No. 78-16 to undue j haste in preparation after being informed by .our office that their response was overdue.
(4) Corrective action was done promptly.
I (5) The licensee has been responsive.
- d. Unresolved Items j (1) Unresolved items were cleared in a timely manner.
I
- (2) The number of unresolved items per inspection has increased. This increase may be attributed in part to increased construction activity 1 at STP and to the focusing of our attention on certain areas because i of recent allegations. Another factor is the recent change (June 1978)
? of the site quality procedures which has caused some confusion in j implementation and documentation.
j (3) None of the unresolved items were escalated to enforcement items.
- l lb 1
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- e. Corporate Managerent in Regulation Matters (1) There was sufficient management representation at exit interviews.
(2) Managementi attitude was receptive.
(3) Signature on licensee letters was of appropriate level.
a (4) Management appears to be involved in QA matters. Their involvement appears to have intensified since our management meetings which took place following our investigations of allegations. Their increased involvement is evidenced by their recent reorganization of the STP project team by which HL&P has become much more active in construction and QA activities. In addition, HL&P management has been frequently 1 observed at the STP site during our inspections.
- f. Effectiveness of CA/QC Program -
1 (oral presentation) i
- 9 Any Other Trends Indicative of Poor Performance Frequent allegations of questionable QA/QC practices.
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[ 'f i'.s 1 1, 2, D;; 50 i.9E; 50-4n i.
t i ENFORCEMENT HISTORY Report No. Dates V ,I_ D_ D_ U_ M/D Remarks _
I 78-01 1/10-13 0 2 0 0 0 6-3/8
- 78-02 1/25-27 0 0 0 0 2 2 Environmental l
78-03 2/21-24 0 0 0 0 2 9-3/4 I
( 78-04 3/21-23 0 1 0 0 0 10 Infraction not cited t
78-05 3/21 0 0 0 0 0 -3/4 Investigation h 78-06 4/04-07 0 0 0 0 0 3-1/2 78-07 4/17-20 0 2 0 0 1 9 78-08 5/16-19 0 0 0 0 0 3 f
^
78-09 5/16-19 0 0 0 0 0 6 Investigation ll 78-10 5/30-6/2 0 0 0 0 2 7 l
78-11 6/11-14 0 0 0 0 0 9 f 78-12 6/25-28 0 0 0 0 0 9 Investigation 78-13 8/15 0 0 0 0 0 - Meeting 78-14 8/22-25 0 0 0 0 0 6-7/8 Investigation 78-15 9/11/14 0 2 0 0 3 6-1/2 Investigation 78-16 10/24-27 0 3 0 0 1 9 l
78-17 12/05-08 0 0 0 1 0 6 l
8 78-18 12/19-22 0 0 0 0 1 6 l
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