POLICY ISSUE 

(Information) 

May 1, 2015 SECY-15-0066

FOR: The Commissioners 

FROM: Mark A. Satorius /RA/

Executive Director for Operations 

SUBJECT: CONSTRUCTION REACTOR OVERSIGHT PROCESS 

SELF-ASSESSMENT FOR CALENDAR YEAR 2014 

PURPOSE: 

The purpose of this paper is to present the results of the U.S. Nuclear Regulatory Commission 

(NRC) staff’s calendar year (CY) 2014 self-assessment of the Construction Reactor Oversight 

Process (cROP). This paper does not address any new commitments. 

SUMMARY: 

The results of the CY 2014 self-assessment show that implementation of the cROP continued to 

meet the agency’s strategic goals of ensuring safety and security through objective, 

risk-informed, understandable, and predictable oversight. The cROP also ensured openness 

and effectiveness in support of the agency’s mission and its strategic goals of safety and 

security. The staff will continue to solicit input from internal and external stakeholders to further 

improve the cROP. 

CONTACT: Thomas J. Kozak, NRO/DCIP 

 301-415-6892
The Commissioners 2 

BACKGROUND: 

The staff performed the CY 2014 self-assessment in accordance with Inspection Manual 

Chapter (IMC) 2522, “Construction Reactor Oversight Process Self-Assessment Program,” 

dated July 28, 2014 (Agencywide Documents Access and Management System (ADAMS) 

Accession No. ML14189A211). The staff has issued three previous cROP self-assessment 

Commission papers and has briefed the Commission annually on the results after the Agency 

Action Review Meeting. The Commission has supplied the staff with direction in the form of a 

staff requirements memorandum (SRM) after these briefings. In SRM-M140603, “Briefing on 

the Results of the Agency Action Review Meeting (AARM), 9:00 A.M., Tuesday, June 3, 2014 

[...],” dated June 16, 2014 (ADAMS Accession No. ML14168A111), the Commission did not 

identify any new cROP requirements for staff action. 

The staff also discussed cROP effectiveness with the Commission during the Briefing on 

Strategic Programmatic Overview of the New Reactor Business Line on September 10, 2014. 

In SRM-M140603, “Briefing on Strategic Programmatic Overview of the New Reactor Business 

Line, 9:30 A.M., Wednesday, September 10, 2014 [...],” dated September 16, 2014 (ADAMS 

Accession No. ML14259A359), the Commission did not identify any new cROP requirements for 

staff action. 

In SECY-11-0111, “Staff Progress in Resolving Issues Associated with Inspections, Tests, 

Analyses, and Acceptance Criteria (ITAAC),” dated August 12, 2011 (ADAMS Accession 

No. ML11174A304), the staff proposed ITAAC and construction experience (ConE) program 

updates be included in the annual cROP self-assessment report beginning in April 2012. The 

Commission subsequently approved this proposal. ITAAC and ConE program updates are 

included in Enclosures 1 and 2, respectively. 

DISCUSSION: 

To ensure that its cROP self-assessment for CY 2014 was comprehensive and robust, the staff 

conducted numerous activities and obtained data from many sources, including the cROP 

performance metrics described in IMC 2522, internal and external stakeholder feedback, and 

direction and insight that the Commission supplied in recent years. The staff analyzed the data 

to gauge cROP effectiveness and potential areas for improvement. The scope of the staff’s 

self-assessment included a review of the key cROP program areas (construction inspection 

program, construction significance determination process (SDP), and construction assessment 

and enforcement programs), cROP communication activities, independent and focused 

evaluations, and cROP resources. 

cROP Program Evaluations

Staff evaluations were in the three key cROP program areas: the construction inspection 

program, construction significance determination process (SDP), and construction assessment 

and enforcement programs. 
The Commissioners 3 

Construction Inspection Program

NRC inspectors independently verified that the AP1000® licensees constructed new reactors in 

accordance with the approved design. During 2014, site construction activities primarily 

involved structural work. Throughout 2014, the staff continued to find quality issues associated 

with modules supplied by their nuclear vendors. To improve the quality of products received, 

the licensees developed corrective actions, including increased oversight of their suppliers. In 

2015, NRC construction inspectors will remain focused on verifying that the licensees ensure 

adequate quality of nuclear materials that are received at the construction sites. 

The staff continued to make progress in developing inspection guidance for all phases of 

construction. No outstanding procedure change requests are required to be resolved to support 

ongoing inspections. Significant accomplishments in 2014 included the issuance of three of the 

planned preoperational testing inspection procedures. 

In September 2014, staff participated in a bilateral exchange with representatives of China’s 

National Nuclear Safety Administration (NNSA) concerning China’s reactor commissioning 

program. The NNSA supplied status updates on China’s reactor commissioning program, 

challenges encountered, and procedure development. The staff reiterated the importance of a 

direct NNSA point of contact to facilitate cooperative exchanges between the NNSA and the 

NRC. The NRC delegation toured the Sanmen AP1000® construction site and participated in 

onsite meetings with Sanmen Nuclear Power Company (SMNPC). SMNPC facilitated detailed 

discussions on an overview of the Sanmen project, licensing progress, challenges and 

estimated scheduling details. The next interaction with NNSA is planned for October 2015 in 

China. 

Construction Significance Determination Process

Guidance for using the construction significance determination process is in Inspection Manual 

Chapter (IMC) 2519, “Construction Significance Determination Process.” All issued construction 

findings were audited using the guidance in IMC 2519 and its appendices. The findings 

included adequate detail to enable an independent auditor to trace through the available 

documentation and reach the same significance color characterization. In addition, it was 

determined during the independent review that the significance of all issued findings was 

appropriately characterized and that all established timeliness goals were met. In 2014, no 

revisions were carried out for the construction significance determination process, and the 

construction significance determination process has no pending updates. The staff will continue 

to monitor significance determination process implementation and consider improvements as 

necessary. 

Construction Performance Assessment and Enforcement Programs

The staff implementation of the construction assessment program ensures that the NRC and 

licensees take appropriate actions to address performance issues commensurate with the 

issues’ safety significance. The staff has not deviated from the guidance in the construction 

action matrix. Vogtle Units 3 and 4, and Virgil C. Summer Units 2 and 3, remained in the 

Licensee Response column of the construction action matrix in CY 2014. 
The Commissioners 4 

On October 9, 2014, the NRC published a proposed revision to the Enforcement Policy for a 

45-day comment period (Federal Register Notice 79 FR 61107). The proposed revision is 

available at ADAMS Accession No. ML14283A451. In this policy revision, the staff plans to 

incorporate the guidance contained in Enforcement Guidance Memorandum (EGM) 11-006, 

“Enforcement Actions Related to the Construction Reactor Oversight Process,” dated 

December 21, 2011 (ADAMS Accession No. ML11354A092). This EGM authorizes the staff to 

disposition construction enforcement actions in a similar manner to its practice for operating 

reactors, consistent with the enforcement description in SECY-10-0140, “Options for Revising 

the Construction Reactor Oversight Process Assessment Program,” dated October 26, 2010 

(ADAMS Accession No. ML102500499), and the Commission’s direction in SRM-SECY-10-

0140, dated March 21, 2011 (ADAMS Accession No. ML110800557). The proposed 

Enforcement Policy revision will be offered to the Commission in a Notation Vote paper in CY 

2015. 

The staff issued NUREG-2165, “Safety Culture Common Language,” in January 2014 to 

formally document the safety culture common language for all NRC programs. NUREG-2165 is 

based on the common language that was agreed to during a January 2013 public workshop and 

was documented in the enclosure to the workshop summary (ADAMS Accession No. 

ML13031A343). Subsequently, the staff incorporated the safety culture common language in 

guidance documents for reactors under construction. 

cROP Communications and Performance Metrics 

The staff supplied external stakeholders the following methods to access to cROP information 

that allowed them to offer feedback. The annual public end-of-cycle performance assessment 

meetings were conducted near Vogtle Units 3 and 4, and Virgil C. Summer Units 2 and 3. 

During the meetings, the staff responded to several questions from members of the public. The 

cROP public web page was modified to include a readily accessible feedback link that allows 

stakeholders to offer direct feedback to the staff by selecting a link that generates an e-mail to 

the cROP team. The staff continued to meet publicly each quarter with external stakeholders. 

In addition, senior Region II and Office of New Reactors (NRO) management visited the two 

construction sites quarterly, during which topics of mutual interest were discussed with senior 

licensee and other consortium management. 

The staff supplied internal stakeholders opportunities to offer input on cROP effectiveness 

through an internal survey, the internal feedback process, periodic meetings, and telephone 

conferences. Results of the internal survey show that the staff generally believes that findings 

can be assigned the proper safety significance in accordance with established guidance. 

However, the staff said the minor and more-than-minor significance guidance could be revised 

based on experience at the sites that are under construction. In 2015, NRO and Region II staff 

will coordinate on enhancing the minor and more-than-minor significance guidance for a more 

consistent implementation. 

The staff met established criteria for all 11 cROP performance metrics as defined in Appendix A, 

“cROP Self-Assessment Metrics,” to IMC 2522, dated November 30, 2012 (ADAMS Accession 

No. ML12289A041). As discussed below, the staff plans to explore more objective performance 

metrics to better assess cROP implementation. 
The Commissioners 5 

Independent and Focused Evaluations

A working group was formed to develop an overall integrated strategy and plan to support an 

effective transition of new reactors from construction to operations. The working group’s efforts 

and recommended program enhancements are contained in the report, “Assessment of the 

Staff's Readiness to Transition Regulatory Oversight and Licensing as New Reactors Proceed 

from Construction to Operation,” dated September 9, 2014 (ADAMS Accession No. 

ML14031A386). Although the working group concluded no immediate transition readiness 

issues existed, the members identified 21 longer term readiness issues, along with 

recommendations. In 2015, the staff has begun to implement action plans to address the 

transition readiness issues. 

In COMSECY-14-0030, “Proposed Suspension of the Reactor Oversight Process 

Self-Assessment for Calendar Year 2014,” dated August 5, 2014 (ADAMS Accession No. 

ML14168A532), the staff requested Commission approval to suspend the annual 

self-assessment of the reactor oversight process (ROP) for CY 2014. In 

SRM-COMSECY-14-0030, “Proposed Suspension of the Reactor Oversight Process 

Self-Assessment for Calendar Year 2014,” dated September 19, 2014 (ADAMS Accession No. 

ML14262A078), the Commission approved this request. The staff is evaluating potential 

improvements to the ROP self-assessment program and exploring more objective performance 

metrics to better assess a mature oversight program. The staff plans to evaluate changes made 

to the ROP self-assessment program and will make appropriate modifications to the cROP 

self-assessment program for use during the CY 2015 cROP self-assessment. The staff will also 

make appropriate changes to the cROP based on other actions that are developed to address 

recommendations and suggestions for further ROP improvements identified during the 

independent ROP assessments conducted by the Government Accountability Office, the NRC 

Office of the Inspector General, and a Commission-directed internal independent review. 

The Office of the Inspector General started an audit of the cROP in late 2014. The staff plans to 

address recommendations that are included in the final report. 

cROP RESOURCES: 

At the end of CY 2014, 48 full-time equivalents (FTEs) assigned to Region II were qualified 

construction inspectors. Two more employees were undergoing construction inspector 

qualifications. Construction resident inspector (CRI) staffing is largely based on the amount and 

type of safety-related activities occurring on site. During CY 2014, the NRC assigned one 

senior CRI and three CRIs to Vogtle Units 3 and 4, and also to Virgil C. Summer Units 2 and 3. 

Additional inspectors were dispatched to the sites on a temporary basis to perform specialty 

inspections and to augment the permanent resident staff. NRC inspection effort remained 

essentially the same in CY 2014 as compared with CY 2013, and was appropriate for the pace 

of construction activity. The staff’s direct inspection effort will increase over the next several 

years as the sites increase safety-related mechanical and electrical construction and start the 

preoperational testing phase. Enclosure 3, “Construction Reactor Oversight Process 

Resources,” further outlines cROP resources. 
The Commissioners 6 

CONCLUSION: 

The self-assessment results for CY 2014 show that the cROP supplied effective oversight by 

meeting program goals and achieving intended outcomes. The cROP was objective, 

risk-informed, understandable, and predictable. The cROP also ensured openness and 

effectiveness in support of the agency’s mission and its strategic goals of safety and security. 

During CY 2014, the staff continued to find opportunities to strengthen program effectiveness 

and implementation. The staff recognizes the value of continuous improvement and, therefore, 

will continue to consider stakeholder feedback in its efforts to apply lessons-learned and 

improve various aspects of the cROP. 

RESOURCES: 

There are no resource implications for fiscal year (FY) 2015. The overall resources for staff’s 

direct inspection effort in support of the Oversight Product Line will need to increase as 

construction inspection activities increase for Vogtle Units 3 and 4 and V.C. Summer Units 2 

and 3. 

Resource needs will be developed as part of the FY 2017 Planning, Budgeting, and 

Performance Management process. 

COORDINATION: 

This paper has been coordinated with the Office of the General Counsel, which has no legal 

objection. The Office of the Chief Financial Officer has reviewed this paper for resource 

implications and has no objections. 

 /RA Michael R. Johnson Acting for/ 

Mark A. Satorius 

Executive Director 

 for Operations 

Enclosures: 

1. Staff Progress in Resolving Issues 

 Associated with ITAAC 

2. Construction Experience Update 

3. Construction Reactor Oversight 

 Process Resources 
 Enclosure 1 

Staff Progress in Resolving Issues Associated with 

Inspections, Tests, Analyses, and Acceptance Criteria 

The U.S. Nuclear Regulatory Commission (NRC) staff continues to carry out and refine the 

processes and guidance developed for inspections, tests, analyses, and acceptance criteria 

(ITAAC) closure. Since the last ITAAC update in SECY-14-0049, “Construction Reactor 

Oversight Process Self-Assessment for Calendar Year 2013,” dated April 24, 2014 (Agencywide 

Documents Access and Management System (ADAMS) Accession No. ML14064A139), the 

staff facilitated 10 public meetings to discuss the development of ITAAC hearing procedures, 

the implementation of ITAAC lessons learned, and other construction inspection program topics. 

Members of the public, industry representatives, and other external stakeholders routinely 

participated in these public meetings. 

ITAAC Closure Notifications 

Through the end of calendar year 2014, Southern Nuclear Operating Co. submitted 20 ITAAC 

closure notifications (ICNs) for Vogtle Electric Generating Plant, Units 3 and 4. South Carolina 

Electric and Gas Co. submitted 18 ICNs for Virgil C. Summer, Units 2 and 3. The staff has 

completed its review of these ICNs. The staff anticipates a marked increase in ICN submittals 

over the next year as licensees complete more ITAAC at the Vogtle and Virgil C. Summer new 

plant construction sites. 

Interim Operations and ITAAC Hearing Procedures

The staff submitted SECY-13-0033, “Allowing Interim Operation Under Title 10 of the Code of 

Federal Regulations Section 52.103,” to the Commission on April 4, 2013 (ADAMS Accession 

No. ML12289A928), and the associated staff requirements memorandum (SRM) was issued on 

July 19, 2013 (ADAMS Accession No. ML13200A115). The SECY informed the Commission of 

issues associated with interim operation while ITAAC hearings were pending. In the SRM, the 

Commission approved the staff’s recommendation that the Commission delegate the NRC’s 

finding under Title 10 of the Code of Federal Regulations, 52.103(g) (10 CFR 52.103(g)) to the 

staff. Since the issuance of SECY-13-0033 and the associated SRM, the staff, the Office of the 

General Counsel, and the Office of Commission Appellate Adjudication have formed an ITAAC 

Hearing Procedures Working Group that developed procedures and templates for use in the 

hearing process. In April 2014, the draft procedures were published in the Federal Register for 

public comment. Public meetings in May and September of 2014 discussed issues related to 

the procedures, and final comments were collected by October 2014. The staff transmitted the 

draft final procedures to the Commission in a SECY notation vote paper dated 

January 20, 2015. 

ITAAC Process Development Documentation 

The staff continues to develop an Office of New Reactors office instruction on the determination 

process to support 10 CFR 52.103. This instruction will guide the review of the licensee’s 

ITAAC completion to support the staff in making the finding in accordance with 

Section 52.103(g) that all acceptance criteria are met. In addition, the instruction will guide the 

staff’s conclusion on the 52.103(g) finding for interim operation under 10 CFR 52.103(c). The 

 
 2 

staff is also developing a template for an Information SECY paper to the Commission informing 

them that the staff is ready to make the 52.103(g) finding. The staff’s efforts in this area have 

been coordinated with activities to develop ITAAC hearing procedures to ensure that both 

processes are complementary and consistent. 

Office of the Inspector General Audit Report

The Office of the Inspector General (OIG) completed an audit of the staff’s ITAAC process and 

made 10 recommendations in a report dated July 12, 2012 (ADAMS Accession No. 

ML12194A434). As stated in the OIG status memorandum issued to staff on April 2, 2015 

(ADAMS Accession No. ML15092A818), 9 of the 10 recommendations have been closed. The 

remaining recommendation, which OIG considers to be resolved, involves the development of a 

change management process to address future change in the ITAAC process. The staff will 

revise its change management procedure to address OIG comments and will provide a status 

update to the OIG before the requested August 31, 2015, due date.
Enclosure 2 

Construction Experience Update

During 2014, the Operating Experience (OpE) and Construction Experience (ConE) Center of 

Expertise continued to collect, evaluate, and communicate OpE and ConE information. The 

Office of New Reactors ConE staff reviewed and evaluated operational events and new reactor 

construction issues for applicability to domestic reactor designs, the new reactor licensing 

process, and the vendor and construction inspection programs. The ConE staff also developed 

written products to communicate lessons learned from the design, construction, and operation 

of commercial nuclear reactors. 

In 2014, the ConE staff published five Information Notices on topics related to safety culture, 

inadequate analysis and functional testing of electrical penetrations, equipment qualification of 

safety related components, crane and heavy lift issues, and the potential for fires resulting from 

unanalyzed electrical circuit failures. The ConE staff also coordinated with the Office of Nuclear 

Reactor Regulation OpE team to address five issues for resolution, which require more 

evaluation by U.S. Nuclear Regulatory Commission (NRC) technical staff. 

The ConE staff coordinated several activities related to agencywide efforts to address 

counterfeit, fraudulent, and suspect items (CFSI). The staff submitted SECY 15-0003, “Staff 

Activities Related to Counterfeit, Fraudulent, and Suspect Items,” to the Commission on 

January 8, 2015 (Agencywide Documents Access and Management System (ADAMS) 

Accession No. ML14240A629) to update the Commission on the status of ongoing staff actions 

related to CFSI. The ConE staff also led the development of draft Regulatory Issue Summary 

(RIS), “Oversight of Counterfeit, Fraudulent, and Suspect Items in the Nuclear Industry,” 

(ADAMS Accession No. ML14192B407) to heighten awareness of existing NRC regulations and 

how they apply to CFSI. The draft RIS was published for public comment in 2014 and is 

expected to be completed in 2015. 

The ConE staff also supported the agency’s international partnerships by exchanging 

information and sharing lessons learned within the Nuclear Energy Agency’s International ConE 

database. In 2014, the ConE staff shared 20 construction-related issues identified through NRC 

inspections and licensee event reporting in the United States.
Enclosure 3 

Construction Reactor Oversight Process (cROP) Resources 

The initial direct inspection effort estimate is 35,000 hours per unit over the course of the 

construction project. This number includes 15,000 hours for inspections, tests, analyses, and 

acceptance criteria (ITAAC)-related inspections; 10,000 hours for construction and operational 

program inspections; 5,000 hours for reactive inspections above the baseline program in 

response to licensee performance issues, allegations, and nonperformance issues/events; and 

5,000 hours for technical support for construction inspection. These have always been stated 

as average values, with initial units likely to require more inspection than subsequent units. 

Table 1 summarizes the U.S. Nuclear Regulatory Commission (NRC) staff resources expended 

at the four AP1000® units under construction, in hours, for the Construction Reactor Oversight 

Process during the past four calendar year (CY) inspection cycles. Tables 2 through 5 reflect 

direct inspection hours expended by calendar year for Virgil C. Summer Unit 2, Virgil C. 

Summer Unit 3, Vogtle Unit 3, and Vogtle Unit 4 respectively. NRC inspection effort remained 

essentially the same in CY 2014 as compared with CY 2013. Through CY 2014, 20 percent to 

23 percent of the estimated direct inspection hours were expended at Virgil C. Summer Unit 2 

and Vogtle Unit 3, and approximately 7 percent of the estimated direct inspection hours were 

expended at Virgil C. Summer Unit 3 and Vogtle Unit 4. As anticipated, the majority of the 

ITAAC direct inspection hours to date were for ITAAC that have not yet been completed by the 

respective licensees. Through CY 2014, actual ITAAC inspection hours have been at or slightly 

above the estimated hours identified in the construction inspection planning and scheduling 

process. However, given the relatively early stages of construction and the relatively small 

population of ITAAC inspections that have been completed, no definitive conclusion can be 

reached regarding expended resources versus the estimated resource expenditures for ITAAC 

inspections. 

ITAAC inspections have been heavily influenced by two issues. The first issue is inspector 

identified deficiencies in the design for reinforcing steel in seismic class 1 structures. The 

second issue is deficiencies identified by the licensees and the inspectors in structural modules 

and items received from suppliers and vendors. Performance in both of these areas has shown 

improvement with time, and fewer hours are being devoted to them. 

The preponderance of ITAAC will be closed near the end of construction; however, the Region 

is performing as much inspection as possible early in the process so as to minimize both the 

inspection resource demand peak and to facilitate timely ITAAC closure. The percentage of 

ITAAC related direct inspection hours expended is fairly consistent with the percentage of 

“Smart Plans” completed. Smart Plans are the detailed inspection plans used to translate the 

general inspection guidance in the Inspection Procedures into plant-specific activities. Tracking 

Smart Plan completion provides the best available method for assessing progress in 

implementing the required cROP inspections. Through CY 2014, approximately 15 percent of 

Smart Plans were complete at Virgil C. Summer Unit 2 and Vogtle Unit 3; approximately 8 

percent were complete at Virgil C. Summer Unit 3; and approximately 9 percent were complete 

at Vogtle Unit 4. 

One item identified during this year’s cROP self-assessment is that direct inspection charges for 

allegation follow-up at the two sites are very low in proportion to the number of allegations 

received. The Office of New Reactors staff is working with Region II staff to ensure direct 

inspection allegation follow-up charges are being accurately tracked. 
2 

The staff’s overall direct inspection effort will increase over the next several years as the units 

proceed through construction and into the preoperational testing phase. The staff will continue 

to monitor direct inspection hours and will appropriately adjust its overall direct construction 

inspection hour estimate of 35,000 up or down, as applicable, as plant construction proceeds. 

 
3 

Table 1 - Actual Construction Inspection Program Direct Inspection 

Hours at AP1000® Units During Calendar Years 2011 - 2014 (Hours) 

Inspection Activity

Hour 

Estimate 

Per Plant

Virgil C. 

Summer 

U2

Virgil C. 

Summer 

U3

Vogtle 

U3

Vogtle 

U4

ITAAC direct 

Inspections 15000 3293 690 3347 921

Program direct 

inspections 10000 3089 1541 3676 1390

Reactive and 

Allegation Inspections 5000 0 0 51 0

Headquarters 

Technical Staff 

Inspection Support*

5000 747 260 824 268

TOTAL 35000 7129 2491 7898 2579

* Headquarters Technical Staff Inspection Support has been tracked only via a 

TAC number that is not linked to a specific docket. Therefore, it is not possible 

to distinguish the hours expended on each unit in this area. The total hours 

have been pro-rated based on inspection hours expended at the four units under 

construction. Through CY 2014, the following percentage of estimated hours 

has been expended: Virgil C. Summer Unit 2: 20 percent; Virgil C. Summer 

Unit 3: 7 percent; Vogtle Unit 3: 23 percent; and Vogtle Unit 4: 7 percent. 

Table 2 - Actual Construction Inspection Program Direct Inspection 

Hours at Virgil C. Summer Unit 2 During Calendar Years 2011 - 2014 

Inspection Activity 

Hour 

Estimate 

Per Plant 

2011 2012 2013 2014 Total 

ITAAC direct 

Inspections 15000 0 636 1269 1388 3293 

Program direct 

inspections 10000 98 1169 1035 787 3089 

Reactive and 

Allegation Inspections 5000 0 0 0 0 0 

Headquarters 

Technical Staff 

Inspection Support* 

5000 13 292 228 214 747 

TOTAL 35000 111 2097 2532 2389 7129 

Total direct inspection and HQs technical support hours expended at Virgil C. Summer Unit 

2 were slightly lower in CY 2014 as compared to CY 2013. Approximately 20 percent of 

the total estimated hours have been expended at Virgil C. Summer Unit 2 through the end 

of CY 2014. 
4 

Table 3 - Actual Construction Inspection Program Direct Inspection 

Hours at Virgil C. Summer Unit 3 During Calendar Years 2011 - 2014 

Inspection Activity 

Hour 

Estimate 

Per Plant 

2011 2012 2013 2014 Total 

ITAAC direct 

Inspections 15000 0 18 313 359 690 

Program direct 

inspections 10000 105 550 597 289 1541 

Reactive and 

Allegation Inspections 5000 0 0 0 0 0 

Headquarters 

Technical Staff 

Inspection Support* 

5000 14 92 90 64 260 

TOTAL 35000 119 660 1000 712 2491 

Total direct inspection and HQs technical support hours expended at Virgil C. Summer Unit 

3 were lower in CY 2014 as compared to CY 2013. Approximately 7 percent of the total 

estimated hours have been expended at Virgil C. Unit 3 through the end of CY 2014. 

Table 4 - Actual Construction Inspection Program Direct Inspection 

Hours at Vogtle Unit 3 During Calendar Years 2011 - 2014 

Inspection Activity 

Hour 

Estimate 

Per Plant 

2011 2012 2013 2014 Total 

ITAAC direct 

Inspections 15000 7 739 1049 1552 3347 

Program direct 

inspections 10000 135 1187 1324 1031 3676 

Reactive and 

Allegation Inspections 5000 0 0 39 12 51 

Headquarters 

Technical Staff 

Inspection Support* 

5000 19 311 239 256 824 

TOTAL 35000 161 2237 2651 2850 7898 

Total direct inspection and HQs technical support hours expended at Vogtle Unit 3 were 

slightly higher in CY 2014 as compared to CY 2013. Approximately 23 percent of the total 

estimated hours have been expended at Vogtle Unit 3 through the end of CY 2014. 

 
5 

Table 5 - Actual Construction Inspection Program Direct Inspection 

Hours at Vogtle Unit 4 During Calendar Years 2011 - 2014 

Inspection Activity 

Hour 

Estimate 

Per Plant 

2011 2012 2013 2014 Total 

ITAAC direct 

Inspections 15000 0 229 301 391 921 

Program direct 

inspections 10000 26 391 572 401 1390 

Reactive and 

Allegation Inspections 5000 0 0 0 0 0 

Headquarters 

Technical Staff 

Inspection Support* 

5000 3 100 86 78 268 

TOTAL 35000 29 721 960 870 2579 

Total direct inspection and HQs technical support hours expended at Vogtle Unit 4 were 

slightly lower in CY 2014 as compared to CY 2013. Approximately 7 percent of the total 

estimated hours have been expended at Vogtle Unit 4 through the end of CY 2014.