ML20129H066
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SEP 2 IS8f i
l HEMORANJUH FOR: SALP Review Group Chairman FH0tt:
Karl V. Seyfrit, director, RIV
SUBJECT:
REGIONAL SALP BOARD REPORT FOR THE SOUTH TEXAS PROJECT, Uni!TS 1 Aliu 2 (Dit 50-49o i 50-499)
The attached Regional S EP Report for the period July 1, 1980 to June 30, 1981, is transmittee for your review in accordance with WRC Hanual Chapter 0516, and appropriate appendices.
I.
SALP Overview l
A.
Tabulaticin of recommended ratings for each functional area:
j 1.
IE Functional Areas a.
Quality Assurance: Below average b.
Site Preparation: All activities completed c.
Containment Structure: Limited work activity / observation i
of work d.
Safety-Related Structures: Average e.
Piping and Hangers:
Limited work activity / observation of work i
f.
Safety-helated Components: Limites work activity / observation of work g.
Electrical: No work activity except storage / maintenance h.
Instrumentation: No work activity except storage / maintenance 1.
Fire Protection: Average j.
Preservice Inspection: No work activity i
k.
Corrective Action and Reporting: 81elow average 1.
Procurement: Limited work activity / observation of work ni.
Design and Design Changes: Average (site field change system) n.
Training: Average 1N 2.
NRR Functional Aree g%
etagsp
-393 POR Licensing: Above Average B.
Recaemanded overall rating for the licensee: Below average s
C.
Action Plan j0 1.
Escalated Enforcement Action: None. However, continuing action by the licensee relative to enforcement action during the
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"N 9/4/81 9/%/81 9/ib/81
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. 9/t.'/81
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SALP Review Group Chairman previous SALP reporting period is discussed in Section III of this report.
Additionally, the licensee must assume that the B&R corrective action effort is entirely satisfactory.
2.
NRC Program Changes:
Resume normal If inspection program in accordance with MC-2512 (proposed revision).
3.
Management Meeting Planned:
SALP meeting only.
4 Status of Action from Previous Appraisals:
Although a formal SALP review was not performed, it was generally recognized that licensee performance during the August 1979 - July 1980 period was below average due to IE Investigation Report 79-19, a proposed Civil Penalty and a Show Cause Order issued April 30, 1980.
- II.
Licensee Performance Evaluation Facility:
South,. Texas Project Licensee:
Houston Lighting and Power Company Facility Information:
Unit 1 Unit 2 Docket No:
50-495 50-499 License No:
CPPR-128 CPPR-129 Date of Issuance:
12/22/75 12/22/75 MSSS:
Westinghouse Westinghouse Mwt:
3817 3817 Appraisal Period:.
September 11, 1981 7/1/80 to 6/30/81 Appraisal Completion Date:
Review Board Members:
W. C. Seidle,.W. A. Crossman, H. 5. Phillips, D. E. Sells, W. G. Hubacek, R. C. Stewart, J. I. Tapia Overall Licensee Performance Evaluation:
This rating is based on review of the QA program corrective action and on observing limited work activity caused by the IE Investigation Report 50-498/79-19; 50-499/79-19, Show Cause and Stop Work Orders imposed on Brown and Root, Inc., the prime contractors, by the licensee.
The below average rating was most heavily influenced by S&R's continued inability to correct the root causes of problems and take corrective action in a timely manner.
The QA program success is largely dependent upon the correction of the cause of deficiencies.
Although Houston Lighting and Power Company (HL&P) has taken affirmative steps and actions in the area described above, the implementation of corrective action measures and procedures is still considered a weak area.
Therefore, the overall rating for licensee performance is below aversge because of HL&P's inability to compel a significant improvement in B&R's performance in this area.
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SALP Review Group Chairman :
III. Performance Analysis l
1.
IE Functional Area Analysis.
I a.
Quality Assurance t
Licensee and NRC quality assurance and inspection effort has been devoted almost entirely to the licensee's Quality Assurance Program.
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The licensee efforts were directed to responding to and correcting j
QA programmatic deficiencies identified in IE Investigation Report j
50-498/79-19; 50-499/79-19, and NRC Show Cause Order issued on i
j April 30, 1980.
The licensee's response, dated July 28, 1980, was 1
a detailed and comprehensive plan to (1) restructure the QA organi-zation; (2) upgrade staffing / training; (3) develop / review procedures; i
j (4) improve management attitudes / actions; (5) clarify stop work l
authority; (6) improve nonconformance system; (7) assure an effec-i tive engineering field change system; (8) assure an effective j
i records management program; and (9) improve the audit systan.
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Work activities includ'ng welding and concrete placement were l
stopped in order to re-examine / repair welds and improve concrete l
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placement controls before performing additional work.
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I NRC follow-up inspection and review of licensee' correcuve action I
relative to IE Report 79-19 noncompliances has been completed and i
[j each of these items was closed; however, implementation in the long l
run has been continuously monitored under the appropriate Show Cause Item.
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l Similar follow-up of Show Cause Order Item in Section V.A has t
resulted in the closecut of item numbers 2, 3, 4, 5, 6 and 10 j-which related to structural backfill, safety-related welding / concrete l
activities, a B&R QA brochure, stop work authority, the nonconform-j ance system, and FSAR statements, respectively.
The following l
items remain open either because corrective action will take an extensive period of time for licensee implementation or the l
corrective action was not completely adequate as follows:
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Item 1:
Have a Management Consultant Review HLP/OR Management, j
Nuclear Construction, QA Program and Organizational Responsibility to Control Design, Procurement, and Construction Activities.
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Especially the control of the Licensee's Prime Contractor, Brown and Root, Inc. (B&R).
j This item remains open because of the licensee's inability to 91 ace i
an effective moratorium on the revision of project procedurer... The i
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Bechtel audit resulting from the Show Cause, recommended a sin j
month moratorium on such revisions, i
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j SALP Review Group Chairman '
i Item 7:
Develop and Implement an Effective System to Control i
Field Design Changes.
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This item remains open because the new system has not been fully implemented.
The last NRC review of this ites determined correc-j tive action to be approximately 90% complete.
i Item 8:
Develop and Implement a more Effective Records Control
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System.
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The nature of this item causes the corrective action to take an j
extensive period of time, i.e., old records must be converted to 1
the new record control system which is a time dependent action.
However, at times the corrective action has bordered on being too
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j Item 9,:
Develop and Implement an Improved Audit System.
l The licensee has done a very good job in upgrading their audit system.
However, the main problem seems to be getting 8&R to take timely and effective corrective action on audit deficiencies.
i Auditors time is needlessly consumed reauditing/following up on i
items identified.
HL&P QA management and the audit group are very j
frustrated with 8&R management's inability or unwillingness to get i
prcblems resolved.
Auditors are assured in writing that deficiencies l
have been corrected only to perform an audit and later find nothing l
l was done to correct the deficiencies.
l NRC follow-up inspection and review of B&R audit system indicates j
their system has been improved; however, IE Inspection Report 50-498/80-18; 50-499/80-18 documented a noncompliance where impasses i.
on audit findings were not escalated to upper management.
IE l
Inspection Report 50-498/81-07; 50-499/81-07 documented 8&R's failure i
i to implement corrective action and commitments made to the NRC
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relative to audit staff levels at the site and in the Houston l
Offices.
Auditor training was also not given as stated in the j
response to Show Cause.
These items were subsequently corrected but only because of NRC/ licensee intervention.
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The closecut of item 9 was also contingent upon an HL&P audit of
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all areas of IE Report 79-19 and the Show Cause to assure corrective action / implementation of commitments to the NRC.
This i
HL&P audit was completed on July 6, 1981, and the audit report, j
H8R-4/3, indicated B&R corrective action was not adequate.
This item remains open to allow more time to assess final corrective i
action.
Two noncompliances were written against this functional area:
(1) failure to escalate audit impasses to higher management, and (2) failure to apply hold tags to nonconforming material.
- However, four of six noncompliances issued during the subject period were
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SALP Review Group Chairman i l
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coded as caused by QA management and in most instances HL&P and B&R management had an opportunity to take appropriate action on an l
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unresolved item but did not take proper action which resulted in j
upgrading the item to violations / infractions.
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b.
Site Preparation and Foundations:
Work Activity Completed l
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Containment Structure I
Limited work has been done relative to containment concrete activities. l However, two noncompliances were identified (1) failure to maintain /
inspect traceability of imbeds, and (2) failure to test for air j
content of grout.
Limited work effort observed since the ifcensee lifted a self-imposed stop work order appeared to be satisfactorily performed.
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I d.
Safety-Related Structures j.
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ona no'ncompliance was identified in this area (1) failure to assure j.
that purchased material (inspection of Nelson stud welding to embeds) conformed to procurement documents.
This welding was performed.and 3
inspected by Bostrom Bergen but was inspec ad by B&R vendor inspectors.
i 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.
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e.
Piping and Hangers l
j Region IV has performed very little inspection in this area for two I
reasons:
(1) NRC efforts have been concentrated on QA programmatic l
j areas discussed in 1 above, and (2) the volume of work activity j
has been low.
In recent months, work has stopped in this area to allow !
i design engineering to catch up.
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Safety-Related Components l
Work activities in this area has been very low relative to setting i
j equipment because:
(1) status of construction, and (2) sandblast i
activities inside Unit 1 Containment and Auxiliary Buildings.
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The NRC had been tracking unresolved items relative to storage 1
and maintenance of safety-related components.
The problem was 4
identified as a generic problem in IE Report 50-498/81-01; 1
l 50-499/41-01.
A noncompliance with multiple examples was documented i
j in the same report:
failure to follow procedure for storage and i
i maintenance of equipment.
Corrective action to date appears to be i
adequate but final follow-up inspection has not been completed.
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j g.
Electrical l
j No work activity has occurred in this area, however, the storage l
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SALP Review Group Chairman !
.g.
Electrical No work activity has occurred in this area, however, the storage and maintenance has been inspected and appears to be generally satisfactory.
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Instrumentation i
See ites g, above. '
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Fire Protection No problems were identified during the reporting period.
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Preservice Inspection:
No work activity j
k.
Corrective Actions and Reporting 1
The co'ntractor (B&R) continues to experience difficulty relative to corrective action.
It also appears that the root cause of the problem associated with NRC and licensee identified deficiencies is that the deficiencies are not effectively corrected and are l
l not corrected in a timely manner.
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l Some improvement has been noted, but the issue is cloudec 1
because of the extreme demands placed on all licensee and con-i tractor organizations by the NRC Show Cause Order which resulted i
in extensive re-examination / repair programs, special technical and QA reviews, organizational restructuring, numerous personnel 1
changes, and rapid turnover of personnel including key manage-i ment positions.
In all fairness, the performance of the con-j tractor site organization should be evaluated during more j
j normal conditions.
j Senior licensee and contractor management must continue to be intimately involved with the corrective action process to assure s
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that this area is improved.
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Licensee reporting of construction deficiencies in accordance with i
10 CFR 50.55(e) reesirements has been satisfactory in all respects.
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The licensee is very open and if anything tends to over report, however,!
this may have been an over rea: tion to several noncompliances issued
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by Region IV and a management meeting in early 1980.
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1.
Procurement t
1 See 'a' above.
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Design and Design Changes See 'a' above.
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Training i,
i See 'a' above.
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SALP Review Group Chairman '
i 2.
NRR Functional Area Licensee activities dealing -with licensing requirements has 1
j improved significantly during the reporting period.
Responses to requests for information have been timely and of good quality J
during the reporting period.
Licensee understanding of NRC requirements is adequate.
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i IV.
Succortino Data and Summaries
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Noncompliances This data is tabulated in Attachment IV-3 and described in various paragraphs under the Area Functional Analysis section of this report.
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2.
Reports Data 1
a.
LER Numbers Reviewed (Not applicable)
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l b.
Construe" ion Deficiency Reports 4
The licensee's system for reporting construction deficiencies I
is located in the Houston offices.
Deficiencies identified on-j site are forwarded to the Incident Review Committee (IRC) for evaluation.
IE Inspection Report 50-498/81-07; 50-499/81-07
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documented a review of this system which included (1) reviewing i
l licensee written reports for 1980, and (2) reviewing 58 IRC evaluations from April 26, 1977 to July 3, 1980.
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i Eleven reports from July 1, 1980 to June 30, 1981 were reviewed i
j and evaluated.
The status of these deficiencies as of July 15, i
1981 is described below:
1 1.
Final Date Report Subject Deficiencies
.Rooorted Date Status (1) Design of Auxiliary Feedwater Pump (All environmental factors not considered in design) 9/26/80 Open (2) Breakdown in QA Program Relative to Application of Paint to Steel i
& Concrete Surfaces Except for Liner Plate.
9/22/80 Open
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(3) Reactor Containment Bldg. Structural Steel teams Loading 9/24/80 Open
SALP Review Group Chairman Final Date Report Subject Deficiencies Reported Date Status (4) Unacceptable Surface Condition of Weld in Main Steam Piping & Secondary Shield Wall Whip Restraints.
9/26/80 Open (5) Cooling of Primary Shield Wall Penetration Insufficient Air Flow Between Reactor Coolant Nozzle &
Seal Plate.
10/17/80 7/8/81 Open (6)
Inadequate Cable Tray Hanger Design 12/5/80 5/8/81 Open (7) Hilti Anchor Bolts Design Strength Inadequate 12/12/80 Open (8) American Bridge Structural Steel Welds Deficiencies 1/8/81 Open (9) Non-approved Hilti Revised QA Manual 4/10/81 Open (10) Faulted Condition Heat Loads in Design of Portions of the HVAC System 5/8/81 Open l
(11) Computer Program Verification 5/8/81 Open A trend was noted relative to the deficiencias reported.
That is, seven of twelve were design problems.
As a result of this trend and other information, a special NRC inspectien of the design engineering organization was requested on May 27, 1981.
That inspection 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.
The status of these items is as follows:
Final Date Report Subject Reported Date Status CONSIP Pump Shaft Failure 6/26/80 9/18/80 Open Steam Generator Water Level Measure-ment System Error 7/8/71 5/7/81 Open
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i SALP Review Group Chairman '
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3.
Licensee Activities
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The licensee's construction-activities have been low during the subject. period because of the NRC Show Cause Order and Stop Work j
Orders imposed by the licensee.
- 4. '
Insoection Activities A special team was assigned to follow up on the IE Investigation 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 devoted to the routine j
j inspection program because of follow-up and reactive inspection.
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5.
Investication and A11ecations Review 1
Twelve investigations were conducted during the subject period which involved 75.6 inspector-hours.
These investigations are summarized below:
Report No.
Sub.iect Results
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(1) 81-24 Three allegations relative to Allegations were not j
(a) painting records, (b) weld confirmed rod oven power loss, (c) RC8-2 j
settlement.
(2) 81-19 Seven allegations relative to Specification, improper (a) improper specification coating; improper coating i
revision; (b) improper appli-records at contractor 4
cation at coatings, (c) design were confimed.
Remainder engineers not qualified, (d) QC were not confirmed.
coating records falsified, (e) coating records not authentic, (f) American Bridge coating records incomplete, (g) improper coating repair.
(3) 81-18 Two allegations relative to The first allegation was (a) B&R foreman intimidating confirmed, however, morale employees, (b) B&R management and personnel problems were i
took no action on Electrical turned over to HL&P 1
Department problems, management.
(4) 81-17 One allegation relative to Allegation confirmed.
(a) site personnel knowing that an NRC investigation was to occur.
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SALP Review Group Chairman Report No.
Subject Results (5)- B1-11 Eleven allegations relative to All allegations confirmed (a) B&R intimidation of employees, except unqualified personnel I
(b) inadequate inspection of and concrete form shift.
materials leaving warehouse, (c) electrical. personnel not qualified, (d) concrete form shifted, (e) HL&P/B&R forewarned of NRC inspection, (f) FREA procedure improper, (g) B&R performing work that should not have been performed, (h) low
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morale, (i) termination shack calibration practices improper, (j) B&R did not advise employees qf results of employee survey, (k) procurement of electrical supplies iniproper.
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(6) 81-06 Oneallegationrelativeto Allegation not confirmed.
(7) 80-34 Four allegations relative to Allegation (d) was confirmed (a) electrical shop records /
but item was not safety-i i
calibration, (b) storage of related.
l safety-related piping i_n lay down area "M", (c) storage of safety related piping in Fab Shop area, (d) B&R piping isometric drawings differ l
from specification sheets.
(8) 80-31 Three allegations relative to Allegation (b) was confirmed (a) B&R foreman fired because and (c) had "some merit."
l he resisted production pressures, i
(b) B&R rehired personnel formerly I
fired because of conditions
_ identified in IE Report 79-19, (c) Cadweld records inadequate and falsified.
(9) 80-29 One allegation-relative to Allegation was not confirmed.
' - (a) drug use at STP must affect quality of construction.
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-(ii) 3C-22 allegati:es elative ::
AIIega:ic s (1) E c (:) =e e (a) oesig e s Of 57: si;i g cct ::=fi-se,..iie (:) as syst::es a e c; ::moetant, t.:- ec 04er :: legi:c.7
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1s oc s: :=-: n=: := si:e, (c) Ei s:-ess Eaiysis f pi:in; systas e.esti:me:.
(12) 50-21 T.c allegati: s eiatiie ::
111epati: s.e e =cfi sec.
(a) A-saaec*. 1as: ecr.:i:mect c; fes:e.ee a.x re. ns falsifie: : srow i._s ectice es=its ( ) mili.-is-f:resa:
ci c:aliftec.
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Es:statec E-1: reme-: A=i: s a.
Ci<fi :e.alties, t4:
C oe s The WC inccsec a SI C.CCC civil oe al:y a c iss:.ec a Seo.
Cause C-oe- : toe ifce see ce 2c-il 2C,15EC. Tme lizacsee
- 41: :.4 civii :e.alty a c : :vicec a ::meles arc ce:aiier res:cese ec July 25, 1520.
In==:na ce wi*.
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Ce k.g.:s: 15,19!ic, a ~,.cii: meeti.q =as hel: :er.een WO are 1i:e set se-i:r ma.agemen: :: cis~;s1 : e sz Seni:r.e: esentatives f os 5&T als a:.a cerle:: es:cese.
. D ese : :ceeci qs
.e e co::.me.tec a c ciatec in : e.hcli: :c. meet i.:ca_
As a result Of : is settirg,.-2.L: s.ama-ize: 111 ::eritme-.s sace in :se written es:cese, comeitaaets sace set.eem MC L c iiredste BL49emer:*, arc M*3eSts Some a* *.ne Oscii:
nettin; in F L2 Te er (57--l-A 533) catec 54 temeer li; 156C.
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SALD Review Gr:.:: Cnairzan.
PaMies :: inte vene recuestec tia: all : nstr.-:.icn een ::e st==ed but 131s recues* <as ce.7ie:. :-5 weyer, :Se Cemstissien ci: ce: ice to have a::elerated nearings en ne 04 : -ti:n fer
- ne c::erating license : ce.ersine the licensee aanagement's entracter anc ::acetance.
These nearings sta nte en.w y 12, a
1951, in Eay City, Texas, anc are ex:ecte: :: ex anc in. late fall 1931.
Tne fc11 w-.:: eff:r. relative : mis enf:: cesent a:.ica is ces:-ice: in ::ner se:tiens cf uis re:O n anc :: vere: :ne entire 5ALD ;:erice.
Ismediate Artica Letters Mine inneciate action letters were issued relative :: =nfining st::o work a:: ices incesed 2:y :M Ifeensee. The f=11:wio; is a sunsary:
(1) Issued July 17, 1980 - licensee self-iacesec 5::: W:rt 0-cer : : neck acecua:y of ::strels for AWS weleer cualifi-catices anc rec:,alifications.
(2) Issuec Cceber 3,1980, :nfirsing licensee's :assitaents regarcing re examinatien, repair, anc resta-cf AWS welcing.
(3) Issuec Cet:ber 22, 1980, ::nfirsing licensee's : mai:ments fer accitional AWS safety-related welcing.
(a) Issued Mcvencer 21, 1950, :nfirming licensee's : ssitzents regarcing initiating ASME welcing a:tivities.
(5) Issued January 5, 1961, :cfirsing ifcensee's commitments regarcing the ASME safety-relate: welcing it-neek ben Plan an resuscii:n of safety-related AW wp Jing.
(5) Issued Ja.cary 13, 1951, ::nfirsing licensee's : msitzents regarding initiating :sciex ::ncreta =crt anivities.
(7) Issued Fecreary 19,1981, :n=erning sucstit::tien cf certain ASE welcing icentifie: in :ne A5ME safety-elatec welcing IC-Week Wer* Man.
(S)
Issuec Maren 31, 1951, :nfirsing licensee's : mait-sents regarcing fu-:ter ifnite: ASE safety-elate welcing as cutline: in licensee's 12-beek ben Plan.
(9) Issuec Acril 15, 1981, = nfi sing licensee's ::asit-sents egarcing ex:ancing ::aclex ::ne eta w::rt a:tivities.
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w, SALP Review Group Chairman 7.
Management Conferences Held Durina Acoraisal Period J.
The following were management meetings held during the SALP report-ing peri.od:
a.
At request of licensee, a management meeting was held on June 17, 1980, to discuss actions being developed regarding Show Cause Order items.
b.
At request of licensee, to discuss actions being taken regard-ing 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 4
status,of Show Cause Order commitments.
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KarlV.Seyfrit.;f[q Director
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Attachments:
As stated 4
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su int.nntni t v-J Docket Ntmuher: 50-498 NUMBER AND HATURE OF ENFORCEMENT ITEMS - CONSTRUCTION REACTORS
, Investigation & I Noncompliances and Deviations unctional Area
- Inspection Severity Level Classification Deviatlons j
MANHOURS I
II III IV V VI Vio.
Infr. Def
. Quality Assurance 622 1
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. Site Preparation & Foundations Activity Comp.
. Containment Structure 32 1
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3
. Safety Related Structures 7
1 2
. Piping & Hangers s
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.. Safety Related Components 21
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. Electrical 3
- .lastrumentation i
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.Ftre Protection
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- 0. Preservice Inspection No 5ctivity 1.-Ccrrective Actions & Reporting included 1 Above
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- 2. Procurement 1
- 3. Design & Design Changes 1
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- 4. Trainino
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For Faclittles in preoperational test ~)fiase; tie following are included
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- 5. Plant Operations. Prep.
NA i
6.. Fuel Loading Preparation NA t
- 7. Maintenance * -
NA
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- 8. 5: cut lty & Safeguards.*
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- 9. Surveillance & Preop. Testing NA
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- 0. Emergency Planning NA
i ATTACHMENT IV-3 Docket Nimdier: 50,-499 NUMBER AND NATURE OF ENFORCEMENT ITEMS - CONSTRUCTION REACTORS unctional Ares Investigation & I r
! nspection Noncompliances anq Deviations Severity Level Classification Deviations l
MANHOURS I
II III IV V VI Vio.
Infr. Def l
. Quality Assurance i
696 1
1
!. Site Preparation & Foundations Activity comp.
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- l. Containment Structure w--
11 9 1
- i. Safety Related Structures 6
1 1
.. Piping & Hangers 3
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..Safaty Related C m __nts
_10 1
. Electrical 2
.I:strumentation
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1 4
. Fire Fratection 1
- 0. Preservice Inspection No Activity
- 1. Corrective Actions & Reporting included l above
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- 2. Procurement i
l 3.-Design & Design Changes
- 4. Traintne For Fac111tles in preoperational test ~pfiase, tie following are included l
- 3. Plant Operat1ons Prep.
NA
- i. Fuel Loading Preparation MA l
F. Maintenance ' -
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- 1. Security & Safeguards -:
_NA l
I
~.- -
- 8. S:rveillance & Preop. Testing NA i
.fmergency Planning NA
-->M-c.
e..
e bec distrib. by RIV:
K. V. Seyfrit, RIV
~
li J. T. Collins, RIV G. L. Madsen, RIY l
W. C. Seidle, RIV W. A. Crossman, RIV
'W. G. Hubacek, RIV' H. S. Phillips RIV R. C. Stewart, RIV L. E. Martin, RIV J. I. Tapia, RIV M. Peranich, HQ l
H. Scherling, HQ D. E. Sells, HQ l
l e
j 1
i i
l l
.. -..