ML20136F877
| ML20136F877 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 08/05/1983 |
| From: | Love R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20136F875 | List: |
| References | |
| NUDOCS 8503260029 | |
| Download: ML20136F877 (68) | |
Text
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UNITto STATES
'* f .S NUCLEAR REGULATORY COMMIS$10N
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MDf0RANDUM FOR: W. S. Little, Chief. Engineering - Branch II THRD: C. C. Williams, Chief, Plant Systems Section TROM: R. S. Love, Reactor Inspector
SUBJECT:
SEPARAIION OF CABLES AND TRAY As a result of difficulties Region III has experienced interpreting and enforcing licensee FSAR commitments relative to the separation of electrical, instrument and control cables at construction sites, D. Hayes and I met with Messrs. Knight and Ross of NRR and their staffs on June 17, 1983 to discuss the following:
. Separation of E0P and IE cable trays
. Separation of Instrument, Control and Power Cables
. Separation of non Class 1E and Class 1E control and instrunent cables in air
. Separation of redundant Class 1E cables.. and non Class 1E and Class 1E cables within panels and control cabinets
. Identification (handling / classification) of non Class 1E cables ,
routed vith Class IE cables Su:r.ary Statement .
NRR representatives felt that the Region III inspectors should inspect to the licensee's criteria contained in the FSAR even,1f they differ fron Regulatory Guide 1.75 and IEEE 384 which they consider to be guides and not requirenents. .
If the criteria contained in 'the TSAR and the licensee's justification for it is unacceptable, NRR will take the necessary steps to obtain correction.
If Region III does not agree with the FSAR criteria, this should be resolved . .
internally between the Region and NRR. In the absence of specific criteria in the TSAR, Region III will enforce the guidance (i.e., Regulatory Guide 1.75 and IEEE 384).
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W. S. Littie. Chief '
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4 The following specific areas were discussed:
- 1. Separation of Cable Trays 1
The basic issue discussed relative to this ites was the separation in general plant areas of trays containing nos Cassa IE cables from those containing Class 1E cables. IEEE 384 requires 3 foot horizontal and !
t 5 foot vertical separation. The AE/ licenses for Byron /Braidwood and l
other plants has specified 3 inches horisontal and 12 inches vertical !
1, and this criteria is stated in the FSAR. I The .h]gLtepresentatives.,p,r.esent_ felt.the.3 inch and,12,iacht ' separation was: acceptable subject to further review against requirements of
- Appendix R.
i Further, they stated that where the 3 inch and 12 inch sepsrettosf is not
- i maintained the 11'censee must install barriers *"
or. justify the lesser -
separarion.
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It was agreed that the IEEE 384 requirements / guidance was for open i ventilated cable trays and not solid bottom trays as used at Byron /
Braidwood, and other Region III Plants.
i It was further understood that in regard to separation of trays con-taining Class IE redundant division cables, the 3 foot and 5 foot
! separation in general plant areas should be maintained. If exceptions ;
are identified by the licensee they should provide justification to ,
NRR. If Region III identifies exceptions they should obtaint (1) I j
correction. (2) satisfactory justification or (3) refer the matter to- ;
NRR.
' Further, if no previous justification existed for the deviation, t then the licensee could be cited. NRR emphasized that physical indep- t
! andence of electrical systems needed to satisfy Appendix R aust be met.
These electrical
- systems involve equipment necessary to take the reactor to hot shutdown.
! 2. Separation of Crass it. Instrument, Control and Power Cables i (single Division)
- i
)
}- The specific issue discussed relative to this ites was the routing of Class 1E instroent, control and low power cables thru a common Junetton box. The generic issue ist can low power cables be routed with instrument cables, control cables, or both at any time. The concern is
{- degradation of the signals on the instrument and/or control cables.by electrical interference from the powet cable.
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- W. 5. Little, Chief ,
AUG 5 1933 l 4 ;
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! NRR agreed that routing low power cables with instrument and/or control I
' cables was a poor practice but did not have any problems with the i specific casa discussed or with routing these cables together for short i
} distances. Further, NRR felt that any problems with interference '
l between cables would be. detected during pre-op and startup testing.
] -
Nowever, Region III questions whether routine pre-op testing can i L i consistently detect such interferences. j
(
geparation of Non Class 1E and Class 1E Cables in Air l 3.
- l l' The specific problem discussed in regard to this ites was the bundling l l' of non Class 1E cables with Class 1E (Control and Instrumentation) i J* cables between the cable trays in the cable spreading room and the !
j' control room cabinets. !
NRR did not feel that this was a problem for the short distances involved (15-20 feet) as long as it was within the licensees TSAR criteria.
- j Novever, Region III and the licensee need specific quantitative criteria ,
t to laPlement and regulate this attribute. In some instances these l 3 criteria are not in the TSAR. !
- 4. Separation of Non Class 1E and Class 1E Cables. in Panels
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j The problem discussed relative to this item was the numerous locations 1, within S&L designed plants where non Class 1E cables were " tie wrapped" i
with Class 1E cables in panels.
I !
l As stated under Item 3 above, NRR did not feel this was a problem con- (
l sidering the short distance the cables were in contact. Novaver, we !
i (R III) conclude that specific quantitative criteria for these excep- ;
tions should be established in the FSAR to facilitate enforcement.
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4 5 5. Separation of Class 1E. Redundant Division Cables in Fanels and Control Cabinets ,
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- The basic problem (generig) discussed concerning this iten was the lack
. of adeguate separation (per IItt 384 and IEEE 420) between redundant .'
division cables within control room cabinets. The licensees /AEs mais- ,
): tain that the cable jacket material provides the equivalent of 6 inches f l of si,e therefore redundant Class 1E cables can be tie wrapped within control, room cabinets.
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. NRA agreed with Region III that the cable jacket would not be considered i a barrier for redundant Class it cables and that 6 inches of air or .
t equilivant must be maintained to the degree rossible in panels and cabinets or provide an engineered justificat'on . for not meeting the ,
- requirement.
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W. S. Lictie, Chief - 4- AUG5 1983
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Identification-(handling / classification) of Non Class 1E Cables Routed with Class IE Cables l The problem discussed was that the licensee /AE has not classified those i
non Class 1E cables which are bundled with Class 1E cables in the cable spreading room or tie wrapped with Class 1E within panels, and cabinets, as associated circuits.
NRR agreed with Region III that by definition these cables are associated circuits and must be treated as such consistent with IEEE 384.
4 l
R. S. IAve Reactor Inspector cc D. W. Hayes, RIII R. Valker, RIII ~*
J. E. Knight, Chief,
- Power Systems Branch T. Rosa, Chief,
, I&C Systems Branch l
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, JUN 051985 Carolina Power and Light Company ATTN: Mr. E. E. Utley Executive Vice President Power Supply and Engineering i and Construction 411 Fayetteville Street
! Raleigh, NC 27602 !
Gentlemen: i
SUBJECT:
REPORT NO. 50-400/85-20 On May 16-19, 1985, NRC inspected activities authorized by NRC Construction Permit No. CPPR-158 for your Shearon Harris facility. At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed inspection report.
Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and
!
- representative records, interviews with personnel, and observation of activities j ,
in progress.
Within the scope of the inspection, no violations or deviations were identified.
l Should you have any questions concerning this letter, please contact us.
i Sincerely,
- t David M. Verre111, Chief Reactor Projects Branch 1 Division of Reactor Projects
Enclosure:
Inspection Report No. 50-400/85-20 cc w/ enc 1:
R. A. Watson, Vice President Harris Nuclear Project R. M. Parsons, Project General Manager ,
I bec w/ enc 1: (See page 2) !
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Carolina Power and Light Company 2 bec w/ enc 1:
NRC Resident Inspector Document Control Desk State of North Carolina EP Section File Ybf.?S I
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UNITED' STATES i i NUCLEAR REGULATORY COMMISSION
- 3
- - J OFFICE OF INSPECTION AND ENFORCEMENT
!( ,/ Washington, D.C. 20555 *
- INSPECTION AND ENFORCEMENT MANUAL O!
CHAPTER 2920 h
CONSTRUCf!ON APPRAISAL TEAM INSPdCTION PROGRAM 2920-01 PURPOSE .
The purpose of this chapter is to describe the methodology for performing the multidisciplined construction appraisal team (CAT) inspections at nuclear power plants under construction. <
2920-02 OBJECTIVE The objective of the CAT inspection program is to determine through an integrated multidisciplined approach that (1) the facility is being" ton-structed and the hardware is being installed in accordance with regulator g requirements and appropriate industry practices, and (2) the applicant'ys management and quality control programs are of fective. The team inspec-
- Atons focus primarily on hardware installation and construction quality.
Documentation is reviewed to the extent necessary to understand the appli-cant's pr,ograms to provide for final hardware installations of appropriate quality. ' Guidance for the development of facility-specific inspection plans is included. The results of the CAT inspection and evaluation provide an input for the assessment of the effectiveness of the regional implementation of the NRC construction inspection programs, and an input for the overview of INPO construction facility audits.
2920-03 DEFINITIONS 03.01 Hardware: Foundations, structures, systems, equipment, and
. components.
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03.02 potential Enforcement 44ed(noP An apparent noncompliance #,
, with specific regulatory requirements or deviation from specific commitments made by the applicant that are identi-fied during the CAT inspection. Regional management of the applicable regional office is responsible for deciding the appropriate enforcement action to be taken in accordance .
with 10 CFR 2. Appendix C.
.. 03.03 Inspector Observations: An item of concern identified dur-( ing the CAT inspection that, while not related to specific regulatory requirements or applicant commitments, i,s a
l 0 2920-03.03 CONSTRUCTION APPRAISAL TEAM INSPECTION PROGRAM o
departure from appropriate engineering / construction practice and is significant enough that applicant management should take corrective action. '
03.04 Applicant or Licensee:
permit.
Utility that holds the construction 03.05 Inteorated Desian Inspection (IDI): .
Multidiscipline design inspection performed to assess the quality of R
- activities on a nuclear power plant project. The R inspection provides a comprehensive examination of the design R development and implementation for a selected plant system. R An IDI may precede or follow a CAT inspection for a specific R or replicate plant.
R l
2920 04 RESPONSIBILITIES AND AUTHORITIES 04.01 Director. Office of Inspection and Enforcement. Selects facili-ties to be inspected based on input from the NRC offices and the regions, and issues the results of inspections. --
,04.02 Director. Division of Inspection Programs. IE.
CAT program. Administers the
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04.03 -7hief. ReactoI, Construction Proarams Branch !E.
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CAI program. Implements the
) 04.04 Reoional Administra'er.
t Determines the scope and schedule for applicant responses to the inspection report and determines final action na potential enforcement findings.
2920 05 IN'$PECTION C0KEPT .
05.01 The concept of CAT inspections at nuclear facilities under construction is based on concurrent inspections and subsequent I. evaluation of the installed hardware quality by a multidiscipli-nary team.
The primary focus of the effort is on actual quality of in situ hardware necessary to with review of documentation to the extent identify applicant's programs.
the strengths and weaknesses of the
- i. The functional areas tnat should be -
considered in the performance of this inspection are listed in 06.0$c tielow.
05.02 The determination of the fa(ility hardware quality and the ef fectiveness of the applicant's programs to provide for appro-
- priate hardware process: quality is made generally by the following i I I
CONSTRUCTION APPRAISAL TEAM . -
- INSPECTION PROGRAM 2920-05.02a I a. Define the scope and depth of the CAT inspections for a particular facility using criteria selected from the
- guidelines provided in Appendix 1 of this manual chapter.
This definition should be based upon consideration of the facility's past inspection history and salient features.
The scope of the inspection is defiled during the planning and preparation phase, and a as the inspection prog esses. ppropriate revisions are made
- b. Determine the quality of hardware as compared with that dictated by appropriate application of design, construc-tion, and maintenance specifications. In addition, the adequacy of the specifications, on the basis of inspector observations, should be judged considering appropriate engineering / construction practices which may or may not be incorporated into the governing specifications such as regulatory guides, NRC staff positions, contensus standards (e.g. , ANSI, IEEE, ASME, ACI, and AISC), and NRC interpre-tations,
- c. The applicant's programs to provide for hardware quality should be compared with the criteria for effective programs-to the extent necessary to understand the strengths and weaknesses of the applicant's programs. The criteria to be utilized are regulatory requirements, app 1(cant commit-
-r; ments, and/or appropriate practices as discussed in 05.02b above. If the app 1(cant is not committed to the appro-l
. priate engineering / construction practices and the appli-cant's pro is (are) inferior to the appropriate practice (s) gram
, this(s)is identified as an observation of applicant program weakness, d.
Verify that the construction programs including quality programs are implemented. This verification is performed during the site inspection by observations of installed hardware, work in progress, discussions with site personnel during reviews,the conduct of the inspection, and quality program e.
Evaluate management involvement by discussions with manage-ment personnel and limited reviews of documentation, aug-mented by information obtained as a result of the efforts described in 05.02d above.
., f.
Evaluate any program weaknesses identified by a preceding R 101 which could be expected to affect installed and R inspected hardware so as to be apparent in an inspection R of hardware quality. Identify for any following 101 R d design related construction problens which should be con- R sidered for followup during 101. R
_ _ . . - A - -
CONSTRUCTION APPRAISAL TEAM 2920-06 -
INSPECTION PROGRAM 2920-06 PROGRAM GUIDANCE 06.01 Program Timetable and Scope. IE management will determine the frequency of the implementation of the CAT inspections and evaluations. The scope of the program at a particular facility
,~ is to accomplish a multidisciplined inspection of the overall quality of the facility's hardware and within a given discipline
- to focus primarily on potential areas of concern. The factors to be considered in the inspection plan development and imple-mentation are delineated in enclosed Appendix 1 of this manual '
chapter. The planning, inspection, and reporting for each facility should be completed within an approximate 3-month period. This schedule provides about 2 weeks for team planning, two 2-week onsite inspection periods separated by a 1- or 2 week preliminary evaluation and plan reassessment period, and a 1-month period for documentation of inspection results.
06.02 Team Member Assignments. Inspector assignments to the CAT R shall be based on the expertise needed to implement the scope R of the inspection planned for a particular facilit/. Consid- R eration will be given to assignments of 101 team members to the R CAT, particularly those who have or are expected to participae R in an 101 on the same or a replicate plant. R 06.03 Regional Participation
- a. The applicable re ional office will be given an opportunity to assign regiona inspectors to the construction appraisal team. Regional personnel that are assigned to CAT will report to the Tean Leider for direction during the conduct of the inspection. Input for the CAT inspection report from assigned regional personnel shall be provided directly to the Team Leader.
- b. The evening before the exit briefing the team will meet to review their findings. The regional of fice is encouraged to be represented at this meeting,
- c. The regional office is encouraged to be represented at the entrance and exit briefings with the applicant.
06.04 Inforntion Acquisition. Before initiating the team planning phase for a f acility inspection, the Team Leader, or his repre- *
. sentative, will contact and/or meet with regional representa-tives and applicant representatives, as necessary, to identify and obtain thformation related to the factors identified in 06.0$b below. The cat inspectors should review the report from R any preceding 101, discuss relevant findings with the 101 Team R Leader and members, and obtain specific information on, any D
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CONSTRUCTION APPRAISAL TEAM .
INSPECTION PROGRAM 2920-06.04
(
problems requiring further investigation during the CAT inspec- R tion. .
R In addition, the team should obtain information about the applicant's document control and filing system; design con-struction, and maintenance criteria; and governing con,struc-tion drawing and specification definition summaries ~ for the various disciplines. This information must be available to the team for the efficient development of a meaningful facility-specific inspection plan. During this time, NRC inspection specialists and contractor personnel should participate in the preparation of the inspection plan.
06.05 Inspection Plannino and Preparation
- a. A key element for a successful team inspection is detailed planning and preparation. The objectives of planning and preparation are
- 1. To identify those elements that are applicable to the specific facility inspection.
- 2. To formulate a detailed inspection plan appropItate f for the particular facility.
The inspection plan
- should be a guide for performing inspections and
. ..- should be revised based on the results of ongoing inspection activities.
- 3. To make specific functional assignments to each team member.
- 4. To define inspection schedules.
L. To familiarize the team members with the facility organization, procedures, specifications, and drawings that define construction and program requirements.
- 6. To indoctrinate team members to the team concept.
Before the start of the onsite inspection the Team Leader should conduct an indoctrination session for the team members on the concept of team inspections and discuss the broad schedule, inspection ground rules, and areas of assignment. As the team refines a
' the elements of the inspection by defining priorities.
inspector capabilities, and site status, detailed inspection assignments are made and parallel activ-ities are identified. The inspection plan scope i should be based on two 2 week periods on site with a 1- or 2 week period separating the two for reassessing and revising the plan.
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CONSTRUCTION APPRAISAL TEAM 2920-06.05b -
INSPECTION PROGRAM
- b. The team member (s) assigned a functional area should ,
develop an inspection plan for that area using Appendix 1 of this chapter as guidance. Appendix 1 may be sup-
. piemented as required by using applicable inspection procedures contained in the IE Manual. The team members will use the following materials in planning the details of and preparing for the onsite inspection:
- 1. Safety Analysis Report and facility design / cons-truction specifications and drawings that define .
requirements and commitments.
- 2. Inspection history -
inspection reports and docket files provide an overview of regional activity and applicant performance and aid in developing prior-ities.
- 3. Licensee reports - reports submitted by the oppli-cant (such as 10 CFR 21 and 50.55(e) reports) provide indications of the ef fectiveness of the applicant's program.
- 4. Applicant maneals -
arrangements should be made to
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obtali the project manual, quality assurance manual, topical reports, and administrative control manuals. O/
, as required. These documents provide the basis of
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management controls at the site and define responsi- M bilities, authorities, interfaces, and procedural
- aspectsofprojectcontrol.
5, Contractual arrangements the degree to which the appilcant acts as his own A/E, use of separate A/E and multiple consultants, and constructor use of multiple contractors are primary inputs into the sample definition required to provide for evalua-tien of interface effectiveness and an adequate cross section of the work of various contractors.
- 6. Construction status - stage of completion will dictate the scope and types of inspections and evaluations appropriate for a particular discipline.
- 7. Organization charts provide the inspectors with an overview of the management interf aces, communicatian
, channels, and the identification of management per-sonnel. Each inspector must develop an understanding of the organizati,on and identify those managers and supervisors to be contacted.
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CONSTRUCTION APPRA!$AL TEAM INSPECTION PROGRAM 2920-06.05b8
- 8. NRC staff positions / interpretations / regulatory guides (RGs) - current NRC (NRR or IE) staff positions /
r interpretations /RGs define the most recent NRC post-tions and should be considered in the detailed plan-
^ ,
ning and the determination of acceptability of the applicant's program.
- 9. Consensus standards - ANS!/ASME/IEEE/ACI/A!$C stan-dards shall be used as applicable.
- 10. Regional management and inspector impressions of l construction adequacy in the various disciplines.
l 11. 10! reports that are specific to, or a replicate of, R the plant where the CAT ins R
! In particular, the system (s)pection willby inspected beany conducted.
preced- R ing IDI should be considered in the CAT hardware R ,
l sample selected for each functional area. The intent R '
i is for the CAT and any related IDI to provide for an R in depth vertical sample examination of a particular R system from design through construction. DupItcation R of effort should be avoided. R
, c. The planning and preparation stage should result in an
"*- Initial inspection plan which will ensure that the objec-tives of thi s chapter are met. It is the responsibility of the Team Leader to integrate each team member's proposed
' plan / schedule / activities into an overall plan and to l coordinate the inspection activities, i .
The inspection plan should be formulated to address the following functional areas as a minimum:
- 1. Civil / structural construction, including design change control l
- 2. Mechanical construction, including design change l control l 3. Electrical power, instrumentation, and controls, l including design change controls
- 4. Welding and nondestructive examination (NDE), inclu-i 1
- ding design change controls l
. CONSTRUCTION APpRA15AL TEAM 2920-06.05c5 INSPECTION PROGRAM
- 5. Traceability and maintenance and storage (both in-place and preinstallation)1 6., QA/QC inspector effectiveness and corrective action systems 1
- 7. System turnover from construction to operation (only at sites that have established the turnover meche-nism)1
- d. The depth of N0E performed by er under the direction of the CAT wl11 be dictated by the particular circumstances at
,. a facility. In special situations and as dictated by relative impertence to completion of the overall inspection scope, limited destructive or semidestructive examinations may be conducted under the direction of the CAT, as ap-proved by the Chief, Reactor Construction Programs tranch.
Such needs must be presented to the applicant as soon as they are identified to provide for their timely completion.
Also, such examinations may require additional contractor assistance, which requires as much advance notice~*as possible.
- e. The initial inspection plan may be revised as the inspec-tion progresses to focus on more meaningful areas. The Team Leader is responsible for arranging / directing changes to the initial inspection plan.
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2920 07 INSPECTION CONDUCT AND DOCUMENTATION 07.01 General ,
All team members should be dedicated for the duration of the inspection. Each day, the Team Leader should conduct a coor-dination meeting of all team members to discuss the day's activities and findings. As a result of such meetings, team members may be given additional assignments or their effort may be redirected.
A 8These areas overlap with a'reas 1, 2, 3, and 4. The inspectors assigned areas 5 4, and 7 and the inssectors assigned areas 1, 2, 3, and 4 will decide '7who inspects what" during the preparation phase.
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CONSTRUCTION APPRAISAL TEAM INSPECTION PROGRAM 2920 07.01
( At the beginning of the inspection the applicant should be asked to appoint representatives as points of contact for each of the, functional areas, as appropriate. It is the responsi-
' bility of the inspector assigned to each of the functional areas to apprise the applicant's representatives of the progress of
, , , , the inspection on a daily basis through informa11 contact. This will expedite the exit meeting conducted by the Team Leader at the end of each onsite period.
07.02 Entrance and Exit Interviews
- a. An entrance interview between senior applicant management -
l and all CAT members shall be held before starting the onsite inspection. The regional office is encouraged to be represented at this meeting. IP 30703, "Hanagement Meeting
- Entrance and Exit Interviews," should be used as guidance when conducting the entrance interview.
l b. An exit interview shall be held between senior applicant i management and the CAT Team Leader at the conclusion of l each of the 2-week inspection periods. Individual CAT i members will participate at the discretion of the Team l Leader. IE management also may attend the exit interviews.
l
' The regional of fice is encouraged to be represented at these meetings. The designated Te .) Leader for any 101 R s f .: ,- scheduled to follow the CAT inspection should be invited R to attend the final exit interview. For a plant where an R
' 101 is not scheduled to follow a CAT and CAT findings R indicate that a limited 10! for the on site design func- R tion may be warranted, the IDI Team Leader also should be R invited to attend the final exit. IP 30703 should be used R used as guidance when conducting the exit interviews.
The exit interview will be used to summarize the find-ings and to convey the significance thereof to senior applicant management. The results of the inspection shall be openly and freely discussed, but the results or findings shall not be given the applicant in writing. This will ensure"That preliminary information is not provided "via draft reports" before the final report is issued.1
- o. .
80nly requests for information ma'y be given the applicant's representative in writing without the approval of the Team Leader. All other information
. given the applicant in writing must be approved by the Team Leader. It i is important to ensure that information requests do not include any infor-mation about inspection results or findings.
.. Ab- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
CONSTRUCTION APPRAl$AL TEAM 2920-07.03 INSPECTION PROGRAM 07.03 Inspection Documentation The tean will prepare an inspection report for issuance by the Director, IE, or his representative, that documents inspection activities and findings identified during the inspection. The
. a. inspection report and related transe,ittal correspondence should be transmitted within about 1 month after completion of the .
onsite inspections.
The CAT inspection concept employed in this procedure includes an evaluation of overall hardware and construction quality and a
] determination of applicant program effectiveness. Therefore, in addition to using specific requirements and commitments as a basis of evaluation, the inspector may be using other criteria for which explicit regulatory requirements may not exist, such as regulatory guides, staff positions and inter l Consequently, in addition to inspection findings,pretations. which are l potential enforcement findings, the report may contain other I observations which of and by themselves, add up to perceived strengths or weaknesses, if it is found that the hardware quality or the applicant's program does not meet these criteria, the finding is considered as an observation of weakness or-inadequacy. The hardware quality or the applicant's program could exceed requirements, commitments, and these other crl- --
teria, so that this program element is superior. In this '
situation, it would be considered as an observation of strength. '_),
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- a. . Inspection Report. The cover page to the report will con-form to IE MC 0610. The body of the report will identify R the scope and results of the inspection. In additiongto identifying potential enforcement findings, each major g inspection topic area discussed will include the other observations of perceived strengths and weaknesses dis-cussed above.
The topic areas addressed should include as a minimum the functional areas listed in 06.0$c above.
The potential enforcement findings together with the other appropriate observations, provide the basis for evaluation of facility hardware quality and the effectiveness of the applicant's system of controls. The report should identify as clearly as possible the perceived reasons that caused the weakness or strength to exist and should not just repeat the weakness or strength, ti. T_ransmittal letter,8 The transmittal letter will generally conform to the example contained in Appendix 2 of this -
manual chapter. .
I 85pecific detailed examples of these items are obtained by referring to previous CAT inspection / evaluation reports.
CONSTRUCTION APPRAISAt. TEAM INSPECTION PROGRAM 2920-07.03c f c. Appendix A - Executive Summary.1 The Executive Summary should summarize the significant overall conclusions and the scope and results of the CAT inspections and evalua-tions.
, ,. d. Appendix B - Potential Enforcement Findinos.8 This appen-dix summarizes any apparent noncompliances with specific regulatory requirements or deviation from specific commit-ments made by the applicant that are identified during the CAT inspections. Explicit references to the detailed section of the inspection report are made for complete descriptions of the bases for the potential findings.
These are referred to the appropriate regional office for
. review and necessary action,
- e. A l pendix C - Inspector Observations.1 This appendix sum-marizes items of concern ioentified during the CAT inspec-tions. These items, while not related to specific regul-l atory requirements or applicant commitments, are departures from appropriate engineering / construction practices and are significant enough that applicant management should take corrective action. Explicit references are made to the-detailed section of the inspection report for complete s
descriptions of the bases for these items. This appendix may not be required for all CAT inspection reports.
- f. Di s tribut_ ion.
- The CAT report will be sent to the appro-
. priate Regional Administrator at the same time it is sent to the applicant. Af ter proprietary clearance the report will be distributed using the region's standard distri-bution for the inspected facility. In addition, the report will be sent to all utility executives using distribution list 15, and to other interested NRC organizations using distribution list IE01. '
- g. Input to Regional Assessments. The Team Leader shall be responsible for the preparation of the assessment docu-mentation as required by lE Office Procedure 0200.
- h. Construction Inspection Procram (MC-2512) Credit. Each in-spector wno was assigned inspection responsibility in a functional area shall provide the Team Leader a list-ing of the extent to which the CAT effort has served to satisfy the MC 2512 program requirements. This infor-mation will be sent to the appropriate regional manage-ment by the Director, Division of Inspection Programs.
-l l$pecific detailed examples of these items are obtained by referring to previous CAT inspection / evaluation reports, m m- ._m------- - - - - - - - - - -
CONSTRUCTION APPRAISAL TEAM 2920-07.03i INSPECTION PROGRAM
- 1. INPO Overview. The overview of the INPO activities related to f acility construction will be conducted in accordance with the NRC/INPO Coordination Plan attached to the April 1983 letter from W. Dircks (NRC) to E. Wilkinson (INPO).
j . Program Chances. Each team member shall provide recommen-dations (if any) to the Team Leader for construction inspection program changes. The Team Leader shall provide ,
the recommendations (as appropriate) to the Chief, Reactor Construction Programs Branch.
2920-08 LIST OF APPENDICES
- 1. Guidance for Inspection Plan Development.
- 2. Sample CAT Inspection Report Transmittal Letter.
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/g3Citg UNITED STAf ts g
.' O . 'g'; NUCLEAR REGULATORY COMMISSION REGION If I
'g 101 MAmstTTA STRttf.N.W.
3, j ATLANTA,eeonesa303:3
%, ...../ JUN 0 51985 l
1 Report No.: 50-400/85-20 Licensee: Carolina Power and Light Company 411 Fayetteville Street 1
Raleigh, NC 27602 Docket No.: 50-400 i i License No.: CPPR-158 Factitty Name: Shearon Harris Nuclear Plant Inspection Conducted: ay 16-19, 1985 Inspectors: to do
. R. Decker d (te 5tgned
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J. L.~ Kreh g h $f (te'51gned Accompanytng Personnel: G. Stoetzel C. Hawley F. McManus u z Approved b 8
El e. Chief
. nd Emergency Preparedness Ohte 5tgnec d
Otytston of Radiation Safety and Safeguards 1
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$UMMARY Scope: This routine l
! in the area of an eme,rgency preparedness exercise. unannounced inspection enta 4
l Results: No violations or deviations were identified.
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REPORT DETAILS
- 1. Persons Contacted Licensee Employees "R. A. Watson, Vice President Harris Nuclear Project
- J. L. Willis, Plant General Manager
, *E. E. Utley, Executive Vice President J "B. J. Furr, Vice President - OT & TS
- C. S. Bohanan, Director - Regulatory Compliance
- R. G. Black, Director Em'ergency Preparedness
'J. M. Collins, Manager - Operations
'J. R. Sipp, Manager - Environmental and Radiation Control "C. Gibson, Assistant to the General Manager "T. C. Morton, Electrical / Instrumentation and Control Maintenance Supervisor
' i. R. Banks, Manager - Corporate Quality Assurance
'A. C. To111 son, Manager - Nuclear Training
'J. D. Hudson, Project Specialist - License Training ,
"J. R. Bohannon, Director Special Projects
- R. B. Starkey, Manager, Environmental Services
- W. W. Webster, Manager, R&CS Section
- D. B. Waters, Principal Engineer - Operations "J. P. Thompson, Operations Supervisor .
- R. T. Garner, Shift Foreman
- H. R. Goodwin, Senior Specialist - Emergency Preparedness
- E. M. Bean, Corporate Communications - Emergency Preparedness Communications
- D. E. Hollar, Associate General Counsel
- A. L. Garrou, Senior Specialist - Emergency Preparedness
- B. W. Morgan, Senior Specialist - Health Physics "J. H. Smith, Director - Nuclear and $1mulator Training
- R. M. Coats, Assistant to Group Executive - Fossil Generation and Power Transmission
- E. E. Johnson, Principal Specialist - Document Services
'J. W. McDuffee, Radiation Control Supervisor
'A. Klemp, Operations Quality Control Supervisor
- C, E. Rose, Operations Quality Control Supervisor
- D. R. Elkins, Radiation Control Foreman "W. H. Batts, Maintenance Supervisor
- H. E. Jackson, Project Engineer - Maintenance
'H Lipa, Environmental and Chemistry Supervisor
- S. Ham 11 ton, Manager - Construction Procurement and Contracts Other licensee employees contacted included engineers, technicians, operators, mechanics, and office personnel.
,2 NRC Resident Inspectors
'G. Maxwell
- R. Prevatte
'At. ended exit interview
- 2. Exit Interview The inspection scope and findings were summarized on May 19, 1985, with those persons indicated in paragraph I above. 1he inspector described the areas inspected and discussed in detail the inspection findings listed below. No dissenting comments were received from the licensee.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.
- 3. Exercise Scenario (82301)
The scenario for the emergency exercise was reviewed to determine that provisions had been made to test the integrated capability and a major portion of the basic elements existing within the licensee, State and local organizations emergency plans and staff as required by 10 CFR 50.47(b)(14),
10 CFR 50, Appendix E, paragraph IV.F and specific criteria in NUREG-0654,Section II.N.
The scenario was reviewed in advance of the scheduled exercise date and was discussed with licensee representatives on several occasions. While no major problems with the scenario were identified during the review, several inconsistencies became apparent during pre exercise practice drills. To preclude the possibility that the inconsistencies might detract from the licensee's overall performance, a new scenario was developed prior to the exercise. The new scenario was consistent with the previously established timelines and was reviewed by the inspectors and the licensee controller organization. All scenario questions were resolved prior to the exercise.
l No violations or deviations were identified.
- 4. Assignment of Responsibility (82301)
This area was observed to determine that primary responsibilities for emergency response by the licensee have been specifically estab.ished and that adequate staff was available to respond to an emergency as required by
10 CFR 50.47(b)(1),10 CFR 50, Appendix E, paragraph IV. A. and specific criteria in NUREG-0654,Section II.A.
The inspectors observed that specific emergency assignments hac been made i for the licensee's emergency response organization and that there was adequate staff available to respond to the simulated emergency. The initial
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l response organization was augmented by designated licensee representatives and the capability for long-term or continuous staffing of the emergency response organization was demonstrated. The inspector had no further questions in this area.
No violations or deviations were identified.
- 5. Onsite Emergency Organization (82301)
The licensee's onsite emergency organization was observed to determine that the responsibilities for emergency response were unambiguously defined, that adequate staffing was provided to insure initial facility accident response in key functional areas at all times, and that the interfaces were specified as required by 10 CFR 50.47(b)(2),10 CFR 50, Appendix E, paragraph IV.A, and specific criteria in NUREG-0654,Section II.B.
The inspectors observed that the initial onsite emergency organization was well defined and that adequate staff was available to fill key functional positions within the emergency organization. Augmentation of the initial emergency response organization was accomplished through mobilization of off-shift personnel and Corporate assistance. The on-duty Shif t Supervisor assumed the duties of Site Emergency Coordinator promptly upon the initiation of the simulated emergency and directed the response until relieved by the Plant General Manager. The inspectors had no further questions in this area.
No violations or deviations were identified. *
- 6. Emergency Response Support and Resources (82301)
This area was observed to determine that arrangements for requesting and effectively using assistance resources have been made, that arrangements to accommodate State and local staff at the licensee's near-site Emergency
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, Operations Facility have been made, and that other organizations capable of augmenting the planned response have been identified as required by 10 CFR 50.47(b)(3), 10 CFR 50, Appendix E, paragraph IV.A, and specific i
criteria in NUREG-0654,Section II.C.
State and local staff were accommodated at the near-site Emergency l
Operations Facility. Licensee contact with offsite organizations was prompt and assistance resources from various agencies were prepared to assist in f the simulated emergency. The inspector had no further questions in this l area.
No violations or deviations were identified.
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- 7. Emergency Classification System,(82301)
This area was observed to determine that a standard emergency classification and action level scheme was in use by the licensee as required by 10 CFR 50.47(b)(4), 10 CFR 50, Appendix E, paragraph IV.C, and specific criteria in NUREG-0654,Section II.D.
An inspector observed that the emergency classification system was in effect as stated in the Radiological Emergency Plan and in the Implementing Procedures. The system appeared to be adequate for the classification of the simulated accident and the emergency procedures provided for initial and continuing mitigating actions during the simulated emergency. The inspector had no further questions in this area.
No violations or deviations were identified.
l 8.
Notification Methods and Procedures (82301)
This atea was observed to determine that procedures have been established I
for notification by the licensee of State and local response organizations and emergency personnel, and that the content of initial and follow up messages to response organizations had been established; and means to provide early notification to the populace within the plume exposure pathway have been established as required by 10 CFR 50.47(b); 10 CFR 50, Appendix E, l
1 paragraph IV.D, and specific criteria in NUREG-0654 Section II.E.
The prompt notification system (PNS) for alerting the public within the
- plume exposure pathway was in place and operational. The system was l
! activated during this exercise to simulate warning the public of significant events occurring at the reactor site.
questions in this area.
The inspector had no further No violations or deviations were identified.
- 9. Emergency Communications (82301)
This area was observed to determine that provisions existed for prompt I
i communications among principal response organizations and emergency personnel as required by 10 CFR 50.47(b)(6), 10 CFR 50, Appendix E, paragraph IV.E, and specific criteria in NUREG-0654,Section II.F.
l Communications among the licensee's emergency response facilities and emergency organization and between the licensee's emergency response organization and offsite authorities were good. No communication related problemp were identified during this exercise.
No violations or deviations were identified.
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- 10. public Education and Information (82301)
This area was observed to determine that information concerning the simulated emergency was made available for dissemination to the public as required by 10 CFR 50.47(b)(7),10 CFR 50, Appendix E, paragraph IV.0, and specific criteria in NUREG-0654,Section II.G.
Information was provided to the media and the public in advance of the exercise. The information included details on how the public would be notified and what initial actions they should take in an emergency. A rumor control program was also in place. A Corporate and Plant Media Center was established and was well equipped and coordinated. The inspector had no further questions in this area.
No violations or deviations were identified.
- 11. Emergency Facilities and Equipment (82301) l This area was observed to determine that adequate emergency facilities and equipment to support an emergency response were provided and maintained as required by 10 CFR 50.47(b)(8),10 CFR 50, Appendix E, paragraph IV.E and specific criteria in NUREG-0654,Section II.H.
i The inspectors observed the activation, staffing and operation of the emergency use response during the facilities and evaluated equipment provided for emergency exercise. ,
a.
Control Room - An inspector observed that Control Room personnel acted promptly to initiate emergency response to the simulated emergency.
Emergency and procedures were readily available and the response was prompt effective. The inspector had no further questions in this area.
b.
i Technical Support Center (TSC) - The TSC was activated and staffed promptly upon notification by the Site Emergency coordinator of the simulated fication. emergency conditions leading to ar. Alert emergency classi-
- The TSC staff appeared to be knowledgeable concerning their emergency responsibilities and TSC operations proceeded smoothly. The TSC staff.appeared to have adequate equipment for the support of the assigned The inspectors had no further questions in this area.
c.
Operations Support Center (OSC) - The OSC was staffed promptly upon activation by the Site Emergency Coordinator. An inspector observed that teams were formed promptly, briefed, and dispatched efficiently.
The inspector had no further questions in this area.
- d. EmdrgencyOperationsFacility(EOF)-TheEOFislocatedattheShearon Harris Energy and Envire .nental Center, about two miles from the reactor site. The facility appears to be adequately designed, equipped and staf fed to support an emergency response. The inspector had no Jurther questions in this area.
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- e. Corporate Emergency Operations Center (CEOC) - The CECC is located in the Raleigh Corporate offices. The facility appears to be adequately equipped and staf fed to support an emergency response. The inspector had no further questions in this area.
No violations or deviations were identified.
- 12. Accident Assessment (82301)
This area was observed to determine that adequate methods, systems and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition were in use as required by 10 CFR 50.47(b)(9),10 CFR 50, Appendix E, paragraph IV.B. and specific criteria in NUREG-0654,Section II.I.
The accident assessment program includes both an engineering assessment of plant status and an assessment of radiological hazards to both onsite and offsite personnel resulting from the accident. During the exercise, the engineering accident assessment team functioned effectively in analyzing the plant status so as to make recommendations to the Site Emergency Coordinator concerning prevent mitigating actions to reduce damage to plant equipment, to release of radioactive materials, and to terminate the emergency condition.
Radiological assessment activities are spread over several groups. A group in the TSC was estimating the radiological impact in the plant based on inplant monitoring and onsite measurements. Radiological effluent data was ,
received in the TSC. The TSC and EOF calculations were done in parallel and compared on a timely basis both with each other and with the results obtained by the State of North Carolina. The results were also compared with the data obtained in the EOF from the offsite monitoring groups.
The dose assessment methods incorporated both detailed meteorological parameters and inplant data to predict the consequences of a radiological release and to evaluate the actual (simulated) release. Default values were available for use should there be any question concerning the reliability of the meteorological instrumentation. The inspector had no further questions in this area.
A helicopter was used to transport field teams as well as for aerial monitoring. No procedures defining aerial monitoring practices were observed to be used. The inspector discussed aerial plume tracking with licensee representatives, including proper procedures such as:
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_- - - - - y __9 -
7 (1) contamination surveys of the helicopter following flight in a plume, (2) description of personnel dosimetry for flight crews, (3) development of maps appropriate for aerial tracking, and (4) radio use (and equipment) consistent with ground teams. The licensee agreed to evaluate the aerial plume tracking system to determine if improvements were necessary. This exercise weakness will be reviewed during a subsequent inspection (50-400/85-20-01).
No violations or deviations were identified.
- 13. protective Responses (82301)
This area was observed to determine that guidelines for protective actions during the emergency, c'onsistent with Federal guidance, were developed and in place, and protective actions for emergency workers, including evacuation of nonessential personnel, were implemented promptly as required by 10 CFR 50.47(b)(10), and specific criteria in NUREG-0654,Section II.J.
An inspector verified that the licensee had and used emergency procedures for formulating protective action recommendations for offsite populations within the 10 mile emergency planning zone. The licensee's protective action recommendations were consistent with the Environmental Protection Agency (EPA) and other criteria, and notifications were made to the appropriate State and local authorities within the 15-minute criteria.
An inspector observed that protective actions were instituted for onsite .
emergency workers which included periodic radiation surveys in the facility, evacuation of nonessential personnel, and consideration of the issuance of potassium iodide to essential personnel. The inspector had no further questions in this area.
No violations or deviations were identified.
- 14. Radiological Exposure Control (82301)
This area was observed to determine that means for controlling radiological exposures, workers andinthat an emergency,' were established and implemented for emergency they included exposure guidelines consistent with EPA recommendations NUREG-0654, Section as II.K.
required by 10 CFR 50.47(b)(11), and specific criteria in An inspector noted that the exercise by radiological exposures were controlled throughout issuing emergency workers supplemental dosimeters and by periodic surveys in the emergency response facilities. Exposure guidelines were in: place for various categories of emergency actions and adequate protective clothing and respiratory protection were available and used as appropriate. The inspector had no further questions in this area.
No violations or deviations were identified.
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- 15. Medical and Public Health Support (82301)
This area was observed to determine that arrangements were made for medical services for contaminated injured individuals as required by 10 CFR 50.47(b)(12),10 CFR 50, Appendix E, paragraph IV.E. and specific criteria in NUREG-0654,Section II.L.
An inspector observed the emergency medical rescue activities at the accident scene, and treatment by the staff at the Rex Hospital. In all portions of the exercise, acceptable judgement was displayed with regard to first aid practices, decontamination of the patient, and contamination control. The inspector had no further questions in this area.
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No violations or deviations were identified.
- 16. Recovery and Reentry Planning (82301)
This area was observed to determine that general plans were made for recovery and re-entry as required by 10 CFR 50.47(b)(13), 10 CFR 50, Appendix E, paragraph IV.H., and specific criteria in NUREG-0654,Section II.M.
The licensee developed general plans and procedures fnr re-entry and recovery which addressed both existing and potential conditions. The plan contained the position / title, authority and responsibilities of each key individual in the recovery organization. A separate staff was employed to develop the recovery plan. The inspector had no further questions in this -
area.
No violations or deviations were identified.
- 17. Exercise Critique (82301)
The licensee's critique o' the emergency exercise was observed to determine that deficiencies identified as a result of the exercise and weaknesses noted in the licensee's emergency response organization were formally presented to licensee management for corrective actions as required' by 10 CFR 50.47(b)(14),10 CFR 50, Appendix E, paragraph IV.E, and specific criteria in NUREG-0654,Section II.N.
The exercise critique was conducted after the conclusion of the exercise.
Licensee management, key exercise participants, and NRC representatives were present. The licensee discussed areas of the exercise in which iterrs for possible improvement were identified. The inspectors determined that the
, critique was comprehensive and adequately addressed weaknesses identified in the licensee's emergency response program during this exercise.
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A public critique was held on May 19, 1985. Representatives from licensee management, the State, local governments, Federal Emergency Management Agency, and the NRC presented their preliminary findings on the exercise.
No violations and deviations were identified.
- 18. Federal Evaluation Team Report (82301)
The report by the Federal Evaluation Team (Regional Assistance Committee and Federal Emergency Management Agency, Region IV staff) concerning the activities of offsite agencies during the exercise will be forwarded by separate correspondence.
No violations or deviations were identified.
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CONSTRUCTION APPRAISAL TEAM '
INSPECTION PROGRAM APPENDIX 1, 2920
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APPENDIX 1 GUIDANCE FOR INSPECTION PLAN DEVELOPMENT A.
- Purpose To provide guidance in developing an inspection plan for conducting a CAT inspection.
B. Scope 3 This planning guidance is intended for all areas covered by the CAT l inspection:
- 1. Civil / structural construction, including design change control
- 2. Mechanical construction, including design change control
- 3. Electrical: power, control and instrumentation construction, including design change control ._
- 4. Welding and NDE, including design change control
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- 5. Material traceability, maintenance, and storage (both in place and preinstallation*
- 6. QA/QC inspector effectiveness and corrective action systems" l l
- 7. System turnover from construction to operation (only at sites that have established the turnover mechanism)* ,
1 This inspection will focus on components, systems, and hardware important to safety to determine conformance to engineering design, regulatory requirements, and applicant commitments. The CAT inspec-tors will concentrate on " hands on" inspections of selected compon-ents, systems, and hardware to evaluate quality and conformance to specifications. To the extent necessary to evaluate deficiencies observed in the hardware, the applicant's construction, inspection and QA procedures, and documentation controlling on going and com-pleted work will be reviewed.
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'These areas overlap with areas 1, 2, 3, and 4. The inspectors assisa==/
areas 5, 6, and 7 and the inspectors assigned areas 1, 2, 3, and 4 w.II decide "who inspects what" during the preparatipn phase. .
CONSTRUCTION APPRAISAL TEAM APPENDIX 1, 2920 INSPECTION PROGRAM ,
C. Plan Preparation
- 1.
- Background Review
, .ln preparing the plan for these inspections the following inform-ation should be reviewed: *
- a. Recent inspection reports (last 6 months)
- b. 10 CFR 50.55(e) reports
- c. Allegations / investigations
- d. FSAR requirements and commitments
- e. National standards (ASME, AWS, ANSI, IEEE, etc.) committed to by the licensee
- f. Construction, inspection, and QA procedures
- g. Drawings --
- h. The 101 report for the same plant or one of similar design. R
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.yr Each inspector should review these documents or portions of docu- '
ments applicable to his assigned technical area. Items a through l
c should be reviewed for the purpose of guiding or focusing the inspections. The inspectors should not spend excessive amounts l
l of time in areas that the region has recently identified as a .
problem area in the inspection reports. Inspection efforts in these areas should be limited to seeing if the problems continue in present work and that corrective action is being taken on previously identified defective work. Areas identified in 10 CFR 50.55(e) reports should be treated in the same manner.
Allegations should not be pursued. These are the responsibility of the Regional Office and/or Office of Investigations.
Items d through g should be reviewed principally to identify lic-ensee commitments and physical characteristics to be used during tne hands on inspections (dimensions, tolerances, accept / reject criteria, materials heat treatment, etc.) -
- 2. Sample Sele: tion
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The follcwing guidance on selecting samples for inspection is prioritized in descending order of importance:
- a. The sample size selected in each area inspected should be e representative of the installed and inspected hardware.
CONSTRUCTION APPRAISAL TEAM INSPECTION PROGRAM APPENDIX 1, 2920
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- b. The samples selected should be representative of the differ-ent contractors and vendors, shop, field, and site work.
- c. Sample should be selected from different buildings on the
' site and if it is a multiunit site, from those units still under construction.
- d. A sample should be selected, in all disciplines, of hardware R associated with the system (s) inspected by any preceding R IDI. R D. Implementation
] 1. Inspect samples of completed installation, after licensee QC I inspections, to determine work conformance to design drawings, specifications, site proccdures, and FSAR requirements.
- 2. Observe ongoing work and interview crafts and QC personnel as to work skills, knowledge of procedures and requirements, and com-pliance with design and procedural requirements.
- 3. ReviewproceduresandQA/QCdocumentationtotheextentnecessaIy t
to evaluate causes of deficiencies observed in hardware or documentation.
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CONSTRUCTION APPRAISAL TEAM INSPECTION PROGRAM APPENDIX 2, 2920 4
APPENDIX 2
, SAMPLE CAT INSPECTION REPORT TRANSMITTAL LETTER DocFet Nos. 50-(number) .
ATTN: (Utility Executive)
Gentlemen:
SUBJECT:
Construction Appraisal Inspection 50- (Report No.)
This refers to the construction appraisal inspection conducted by the Office of Inspection and Enforcement (IE) on (dates) at (location). The construction appraisal team (CAT) was composed of members of IE. The team was provided technical assistance by a number of highly qualified contractor personnel. This inspection covered construction activities !
authorized by NRC Construction Permit CPPR-(no.).
The enclosed report identifies the areas examined during the inspec5fon.
Within these areas, the effort consisted of detailed inspection of selected hardware after quality control inspections, a comprehensive
,. __ review of your quality assurance program, examination of procedures and
,' records, observation of work activities, and interviews with management and other personnel. <
Appendix A to this letter is an Executive Summary of the results of the inspection and of the conclusions reached by this office.
(Short statement of key conclusions) ppendix B to this letter contains a list of potential enforcement actions based on CAT inspector observations. These have been referred to the Region (no.) Office for review and necessary action.
Appendix C to this letter contains a list of CAT inspector observations relating to matters which, while not specific regulatory requirements, are considered to be of sufficient importance to quality construction to warrant (utility name) management attention and appropriate action.
l In accordance with 10 CFR 2.790(a), a copy of this letter and the enclos-
'. ures will be placed in the NRC Fublic Document Room. No reply to this R letter *is required at this time. You will be required to respond to these R findings after a decision is made regarding appropriate enforcement action. R I
1 CONSTRUCTION APPRASAIL TEAM APPENDIX 2, 2920 INSPECTION PROGRAM ,
Should you have any qu.estions about this' inspection, please contact us or the Region (no.) Office.
Sincerely,
, Director Office of Inspection and Enforcement
Enclosures:
- 1. Appendix A - Executive Sumary
- 2. Appendix 8 - Potential Enforcement Findings
- 3. . Appendix C - Inspector Observations
- 4. Inspection Report 50- (Report No.)
END . .
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