ML20098A903

Forwards Meeting Summary of 840906 Open Briefing on Status of Const Assessment Program & Progress Rept for Aug 1984. Next Briefing Meeting Scheduled for 841004.Viewgraphs Encl

ML20098A903
Person / Time
Site:	Braidwood
Issue date:	09/13/1984
From:	Danni Smith COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
(0295J), (295J), NUDOCS 8409250303
Download: ML20098A903 (73)

Text

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h Commonwealth Edison

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) One First Nationzi Plaza. Chicago, Illinois

\\ ^/ f Address R ply to: Post Office Box 707

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/ Chicago, Illinois 60690 N..

September 13, 1984 PRINCIPAL STAFF[

RA DRP Mr. James G. Keppler D/RA DRS Regional Administrator - Region III

'RC DRSS U.S. Nuclear Regulatory Consission PA0 ML 799 Roosevelt Road SGA OL Glen Ellyn, Illinois 60137 EIC OI

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DRMA FILE feo

Subject:

Status Briefing on BCAP Held on September 6, 1984 at Mazon EOF

Reference:

(a) J.J.O'Connor letter to J.G.Keppler "Braidwood Construction Assessment Program (BCAP)" dated June 22, 1984

~

Dear Mr. Keppler:

The first open briefing on the status of-the BCAP effort (Reference (a))

was provided to the NRC on September 6, 1984 at Mazon EOF.

Forwarded herewith is a meeting summary including a copy of the visual-aid material used in the presentations. The next briefing meeting is scheduled for 9:00 a.m. on October 4, 1984 at the Mazon EOF.

Also forwarded herewith for your information is the BCAP Director's Progress Report for the month of August 1984.

Please direct any questions relating to BCAP to Mike Wallace, Assistant Manager of Projects and Braidwood Project Manager.

truly yours 1

1 l

David H. Smith Nuclear Licensing Administrator Attachments cc: NRC Resident Inspector - Braidwood NRC BCAP Inspector - Braidwood (0295J) 8409250303 840913

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DR ADOCK 05000456 6.feoI b

.s Meeting Summary u

BCAP NRC/ CECO /ERC Monthly Meeting September 6, 1984 9:00 a.m.

Mazon EOF

_ The meeting-was opened with'a brief statement by the NRC Region III Administrator, J.-Keppler, giving the context of and purpose for:this meeting, that is, to discuss the BCAP, its progress, and the Independent Expert

-Overview Grovo's (1800)' review of the BCAP.

,The following is the agenda utilized for the remainder of the meeting.

I.

Introduction Presented by the Ceco Manager of Projects to provide the major topics of the presentation (see enclosure 1).

II.-

'BCAP Status Overview

. Presented by the Braidwood Project Manager to provide a history and context of the BCAP (see enclosure 2).

III. BCAP Progress Presented by the BCAP. Director to provide the BCAP's achievements to date and tae current status (see enclosure 3).

IV.

BCAP QA Overview Presented by the Assistant Manager of Quality Assurance to describe the overview activities to date of the Ceco BCAP QA group (see enclosure 4).

V.

150G Progress Report

_ Presented'by the Project Manager of the IBOG to describe the overview activities to date of the IBOG (see enclosure 5).

Additional items discussed during the meeting are included in enclosure 6.

The attendance for the meeting is provided in enclosure 7.

The meeting

' adjourned at.11:30 a.m.

.- (0298J)

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BRAIDWOOD STAllQR BCAP STATUS MEETING SEPTEMBER 6, 1984 I.

INTRODUCTION TOM MAIMAN

..d II.

BCAP STATUS OVERVIEW MIKE WALLACE III.

BCAP PROGRESS REPORT NINU KAUSHAL I

IV.

' QUALITY ASSURANCE PROGRESS REPORT GENE FITZPATRICK V.

INDEPENDENT EXPERT OVERVIEW GROUP PROGRESS REPORT JOHN HANSEL

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BCAP SCOPE A PROGRAM 0F INSPECTIONS AND REVIEWS UNDERTAKEN AS A PRUDENT MEASURE TO ANSWER ANY LEGITIMATE QUESTIONS CONCERNING THE QUALITY OF CONSTRUCTION.

PROGRAM-CHRONOLOGY PROGRAM DEVELOPMENT BEGAN FEBRUARY, 1984 INDEPENDENT EXPERT OVERVIEW GROUP RETAINED MARCH 19, 1984 PROGRAM PRESENTED TO NRC AT PUBLIC MEETING JUNE 8, 1984 BCAP TASK FORCE FORMATION BEGAN JUNE 11, 1984 L

PROGRAM DOCUMENT SUBMITTED TO NRC JUNE 22, 1984 NRC COMMENTS ON PROGRAM DOCUMENT JULY 27, 1984 CECO RESPONSE TO NRC COMMENTS AUGUST 30, 1984 FIRST MONTHLY STATUS MEETING SEPTEMBER 6, 1984

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-QHJECTIVES OF BCAP

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TO ASSURE THAT:

N0 PROGRAMMATIC DESIGN-SIGNIFICANT PROBLEMS IN CONSTRUCTION, WHICH HAVE NOT BEEN IDENTIFIED AND ADDRESSED ON-SITE CONTRACTORS' PROCEDURES GOVERNING ONGOING SAFETY-RELATED CONSTRUCTION AND QUALITY ASSURANCE ACTIVITIES ADDRESS ALL APPLICABLE DESIGN AND REGULATORY REQUIREMENTS WHERE PAST CONSTRUCTION PROBLEMS HAVE BEEN IDENTIFIED WHICH RESULTED IN SIGNIFICANT CORRECTIVE ACTIONS, SUCH CORRECTIVE ACTIONS HAVE

-BEEN ADEQUATELY IMPLEMENTED AND DOCUMENTED.

PROGRAM ELEMENTS CSR C0'NSTRUCTION SAMPLE REINSPECTION RPSR REVERIFICATION OF PROCEDURES TO SPECIFICATION REQUIREMENTS I

RSCAP REVIEW 0F SIGNIFICANT CORRECTIVE ACTION PROGRAMS

/

t BASIS FOR CONFIDENCE IN OUALITY OF CONSTRUCTION BASFD ON REGULATORY REQUIREMENTS CONTRACTOR QUALITY ASSURANCE /0UALITY CONTROL PROGRAMS, AUDITS, AND INSPECTIONS ASSURE QUALITY IN DESIGN, PROCURENENT, AND CONSTRUCTION INSPECTIONS BY INDEPENDENT TESTING AGENCY EDIS0N QUALITY ASSURANCE PROGRAM AUDITS AND' SURVEILLANCES 0VERVIEW 0F CONTRACTOR QUALITY ASSURANCE /0UALITY CONTROL PROGRAMS EDIS0N QUALITY ASSURANCE OVERINSPECTIONS A SECOND LEVEL 0F INSPECTION FOR ADDED CONFIDENCE THAT WORK WAS PERFORMED PROPERLY CORRECTIVE ACTION PROGRAMS /REINSPECTIONS IDENTIFIED CONSTRUCTION DEFICIENCIES HAVE BEEN CORRECTED, AND, WHERE NECESSARY, REINSPECTIONS HAVE BEEN PERFORMED

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OTHER MEASURES TO ENSURE THAT SIGNIFICANT DISCREPANCIES ARE IDENTIFIED AND ADDRESSED INP0 DESIGN AND CONSTRUCTION EVALUATION PERFORMED TO ASSIST IN ACHIEVING HIGHEST STANDARDS OF EXCELLENCE IN ACHIEVING MANAGEMENT REVIEW REVIEWS OF SPECIFIC PROJECT AREAS AS WEl.L AS BROAD SCOPE OF ACTIVITIES, BY EXPERIENCED INDIVIDUALS, TO IDENTIFY AREAS OF IMPROVEMENT BCAP A BROAD BASED PROGRAM 0F INSPECTIONS AND REVIEWS i

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(0868D)

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I FIGURE 1 BCAP ORGANIZATIONAL CHART

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Commonwealth Edison Company Chairman and President Manager of Manager of Projects Quality Assurance

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Assistant Manager Braidwood Independent Quality Assurance Project Manager Expert Overview Group 4

Site OA General Supv.

BCAP Director BCAP Q4 BCAP Task Force Overview Group Commonwealth Edison Contractors Consultant Groups (07054)

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APPROACH TO ENSURE QUALITY OF BCAP EFFORT BCAP TASK FORCE STAFFING STONE & WEBSTER AND DANIEL CONSTRUCTION COMPRISE MAJORITY OF TASK FORCE ALL PERSONNEL DEDICATED TOTALLY TO BCAP BCAP DIRECTOR ON EQUAL LEVEL WITH CONSTRUCTION,

'STARTUP, OPERATING, LICENSING AND COMPLIANCE BCAP HIGHLY STRUCTURED WITH DETAILED PLANS, PROCEDURES, CHECKLISTS AND INSTRUCTIONS.

OVERVIEWED BY SEPARATE SITE QUALITY ASSURANCE GROUP OVERVIEWED BY INDEPENDENT EXPERT OVERVIEW GROUP REPORTING TO MANAGER OF PROJECTS, UNDER PROTOCOL OPEN MONTHLY NRC STAFF BRIEFING NRC INVOLVEMENT l

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BCAP

SUMMARY

STATUS

^

PLANNING COMPLETE AND ORGANIZATION IN PLACE 4

PLANS AND PROCEDURES FOR BCAP WORK ESSENTIALLY COMPLETED PREPARATION OF INSTRUCTIONS AND CHECKLISTS IN PROGRESS RSCAP REVIEW IN PROGRESS TRAINING AND CERTIFICATION OF INSPECTORS

. ESSENTIALLY COMPLETE

. INSPECTIONS (CSR) EXPECTED TO' START NEXT W EK

ENCLOSOC3 )

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PRESENTATION OUTLINE

.sy ESTABLISHMENT 0F THE BCAP EFFORT OVERALL WORK PLAN

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BCAP PROGRESS CSR RPSR-l-

RSCAP BCAP ORGANIZATION-PLANNED MANPOWER l

MANPOWER STATUS i

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SUMMARY

STATUS L

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ESTABLISHMENT OF THE BCAP EFFORT BCAP. MOBILIZED ON JUNE 8, 1984

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ON JUNE 11, 1984, TEAM 0F 12 STARTED WORK.

BY END OF JUNE, ORGANIZATION ESTABLISHED AND OVERALL WORK PLAN DEVELOPED.

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BCAP DOCUMENT IS THE PROGRAM BASIS.

DEVELOP FOUR SUBTIER PLANS.

1 OVERVIEW PLAN 3 ELEMENT PLANS (ONE~PER' ELEMENT)

IDENTIFY INITIAL LIST OF PROCEDURES.

WRITE PLANS AND PROCEDURES.

WALK THROUGH THE PROCEDURES.

INCORPORATE FEEDBACK FROM THE WALK-THROUGHS.

PREPARE CHECKLISTS AND INSTRUCTIONS.

TRAIN AND CERTIFY INSPECTORS CARRY 0VT THE WORK.

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LC CSR - CONSTRUCTION SAMPLE REINSPECTION OBJECTIVE-REINSPECT A SUFFICIENT SAMPLE OF COMPLETED SAFETY-RELATED CONSTRUCTION ACTIVITIES TO VERIFY CONFORMANCE TO DESIGN.

ADDITIONALLY, THE DOCUMENTATION FOR THE SAMPLE REINSPECTED WILL BE REVIEWED TO ASSURE THAT IT IS COMPLETE AND ACCURATE.

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CSR ACTIVITIES THESE ARE:

DEFINE CONSTRUCTION CATEGORIES ESTABLISH POPULATIONS PREPARE CHECKLISTS FOR HARDWARE INSPECTIONS I

FOR DOCUMENTATION REVIEWS SELECT SAMPLE PREPARE VERIFICATION PACKAGE PERFORM INSPECTIONS AND REVIEWS PROCESS DISCREPANCIES ANALYZE / EVALUATE RESULTS

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J CSR PROGRESS 0VERALL PLAN PREPARED AND APPROVED

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5 0UT OF 6 PROCEDURES COMPLETED ALL (36) CONSTRUCTION CATEGORIES IDENTIFIED n

4 CHECKLISTS COMPLETED, 8 IN PROGRESS (36 REQUIRED)-

SAMPLE DEFINITION SELECTION IN PROGRESS.

INSPECTION PACKAGE PREPARATION IN PROGRESS, TRAINING AND CERTIFICATION OF INSPECTORS IN l

PROGRESS l-i.

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RPSR - REVIEW 0F PROCEDURES TO SPECIFICATION REQUIREMENTS OBJECTIVE-TO ASSURE THAT ON-SITE CONTRACTORS' PROCEDURES GOVERNING ON-G0ING AND Fl!TURE SAFETY-RELATED CONSTRUCTION AND INSPECTION ACTIVITIES ADDRESS ALL APPLICABLE DESIGN AND REGULATORY REQUIREMENTS.

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RESR ACTIVITIES DETERMINE DESIGN AND REGULATORY REQUIREMENTS i.

IDENTIFY APPLICABLE CONTRACTOR PROCEDURES COMPARE DESIGN AND REGULATORY RE0blREMENTS T0

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PROCEDURAL CONTENT DOCUMENT AND RESOLVE DIFFERENCES 0194l

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RPSR PROGRESS OVERALL PLAN PREPARED AND APPROVED RPSR PROCEDURES COMPLETED AND APPROVED APPLICABLE S & L SPECIFICATIONS AND CONTRACT 0R' PROCEDURES IDENTIFIED PREPARATORY WOR;( FOR COMPLETION OF CHECKLISTS

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FOR PROCEDURE REVIEW IN PROGRESS PLANNING FOR REVIEW AGAINST FSAR CONSTRUCTION.

COMMITMENTS IN PROGRESS j :-

_.. _.. _. _.. _. _.. _. _ -,..... _. _ _. _ _ -.. ~. _. _..,.... _ _ _. _.. _ _ _. _..

r REVIEW OF SIGNIFICANT CORRECTIVE ACTION PROGRAMS (RSCAP)

.8 OBJECTIVE:

TO DETERMINE THAT "WHERE PAST CONSTRUCTION PROBLEMS'HAVE BEEN 4

IDENTIFIED WHICH RESULTED IN SIGNIFICANT CORRECTIVE ACTIONS,

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SUCH CORRECTIVE-ACTIONS HAVE BEEN ADEQUATELY IMPLEMENTED AND DOCUMENTED" l-L l.

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RSCAP SCOPE SIGNIFICANT CORRECTIVE ACTION PROGRAMS INCLUDED UNDER RSCAP ARE:

A.

REINSPECTION OF SAFETY-RELATED MECHANICAL EQUIPMENT B.

QUALITY CONTROL REINSPECTION C.

PIPIN3 HEAT NUMBER TRACEABILITY D.

QUALITY CONTROL STRUCTURAL STEEL REVIEW (0CSSR)

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ELECTRICAL INSTALLATION DOCUMENT REVIEW F.

SAFETY-RELATED PIPE SUPPORTS G.

HVAC WELDING H.

HVAC CONFIGURATION I.

HVAC DUCT STIFFENER AND FITTING DETAIL J.

INSTRUMENTATION INSTALLATION VERIFICATION K.

NSSS COMPONENT SUPPORT VERIFICATION

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OVERALL PLAN PREPARED AND APPROVED DETAILED IMPLEMENTING PROCEDURE PREPARED, APPROVED WALKTHROUGH OF THE PROCEDURE COMPLETED &

FEEDBACK FROM WALKTHROUGH INCORPORATED REVIEW INITIATED ON 5 0F THE 11 CAP'S IN PROGRESS

- MINOR REVISIONS TO PLAN & PROCEDURE

Ib BCAP - OVERALL PROGRESS OVERVIEW PLAN AND PLANS FOR EACH ELEMENT PREPARED AND APPROVED.

16 0UT OF 17 PROCEDURES COMPLETED AND APPROVED.

DRAFT:0F REMAINING ONE COMPLETED.

SOME REVISIONS BASED ON IEOG COMMENTS IN PROGRESS.

TRAINING AND CERTIFICATION OF INSPECTORS ALMOST COMPLETE.

PREPARATORY WORK FOR COMPLETION OF INSPECTION

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PACKAGES (CSR) AND PROCEDURE REVIEW (RPSR) IS PROCEDING.

DETAILED PLANNING IN PROGRESS.

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BCAP ORGANIZATION

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OmlIIEL SENI0ft ASSISTAIIT MAII4Xit TATI M Larryteelst

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Henzo C11nton i

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ASSISTAllT DIRECTCIt ASSISTAlli OIRECT0ft i

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f ASSISTANT DIRECTOR George Orlov TECHNICAL ASSISTANI J. Cumiskey TECielICAL ASSISTANT

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.T. Ryan CSR SUPERVISOR RPSR SUPERVISOR Al Patterson P. Amoruso ASST. SUPERVISOR ASST. SUPERVISOR Jim Thanpson Ralph Moderski NDE ENGINEER C. Larsen MECHANICAL HVAC ELECTRICAL CIVIL & STRUCTURAL MECHANICAL ELECTRICAL I

STRUCilRAL AND LEAD LEAD LEAD PIPING LEAD AND LEAD

& HVAC PIPING LEAD LEAD Len Duss Phil Mule Dave Patel R. Baumgarten T. Vaughn Jr.

V. Turner N. Banerjee a

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-6 ASSISTANT DIRECTOR Bob Byers CLERICAL SUPPORT Jeani Livingston Shirley Swain-Sharon Gill *-

Glorla ledesma *.-

Joan Stybr

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• RSCAP SUPERVISOR INSPECTION SUPERVISOR ADMINISTRATIVE ENGINEER Mike Dougherty Menzo Clinton Tom Flynn ASST SUPERVISOR COORDINATOR F. Musselman CERT /TRNG ADMINISTRATOR-L. Williams MECHANICAL ELECTRICAL STRUCTURAL Q.C.,

MEQlANICAL ELEC1RICAL STRUCTURAL AND LEAD AND INSPECTOR AND LEAD AND PIPING LE/D HVAC LEAD PIPING LEAD INAC LEAD Gene Kurtz Mike Kopp L. Rouen L. Strope Ed Shevlin Darrold Burlison Joe Sexton

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BCAP

SUMMARY

STATUS PLANNING COMPLETE AND ORGANIZATION IN PLACE PLANS AND PROCEDURES FOR BCAP WORK ESSENTIALLY COMPLETED PREPARATION OF INSTRUCTIONS AND CHECKLISTS IN PROGRESS RSCAP REVIEW IN PROGRESS 4 TRAINING AND CERTIFICATION OF INSPECTORS ESSENTIALLY COMPLETE INSPECTIONS (CSR) EXPECTED TO START NEXT W EK

5 a c t os a n.5 % 9 - .e t BCAP 0.A. TOPICS S ORGANIZATION 8 t' PERSONNEL 4 DEVELOPMENT EFFORTS 6 REVIEW EFFORTS f e AUDITS /SURVEILLANCES i (0059B)-

FIGURE 1 BCAP ORGANIZATIONAL CHART Commonwealth Edison Company Chairman and President Manager of Manager of Projects Quality Assurance . _. = Assistant Manager Braidwood Independent Quality Assurance Project Manager Expert Overview Group Site OA General Sun BCAP Supervisor BCAP QA BCAP Task Force Overview Group v 7 Commonwealth Edison Contractors Consultant Groups ) (0705d)

v. MANANGER Q.A. ASST. MGR. Q.A. 4 V - y O.A. Q.A. l _y SUPT. GEN. SUPVR. I I i 1 lBCAP} lDESIGNJ IPTL) l I I i 1 LEAD ENG. LEAD ENG. LEAD ENG. SUPVR. CSR RPSR RSCAP OVERINSPECT GROUP Q.A. ENGINEERS Q.A. ENGINEERS Q.A. ENGINEERS INSPECTORS AND AND AND uTECH. SPECIALISTS TECH. SPECIALISTS TECH. SPECIALISTS E o.. 9 e g

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BCAP 0.A. PERSONNFL-POSITIONS CURRENT EST PEAK SUPERVISOR, ENGINEERS, SPECIALISTS 7 8 OVERINSPECTION GROUP 9 10 SUPPORT _3. _3. TOTAL 19 21 l I 's 't (0059B) -n.,--, emy,- .-7,n------er-- n-.g-,-,- oge,,,, vn,-->,rr,nr,-.--emmmm,-mm-w-ww-e~,-mm, e-,-m,.+---r.mme~wwe-w->~2 e

PERSONNEL EXPERIENCE LEVELS (AVERAGE YEARS) OVERALL NUCLEAR Q.A. i j GENERAL SUPERVISOR - Q.A. LEAD ELEMENT ENGINEERS 21.9 13.4 3.9 OVERINSPECTION SUPERVISOR 0.A. ENGINEERS / TECH. SPECIALISTS 1 INSPECTORS 14 7.4 l i i i i I } i l 1: (0059B) )

QUALITY ASSURANCE - BCAP OVERVIEW BCAP ~ PROGRAM DOCUMENT 0.A. PLAN FOR BCAP 0 WHO 8 HOW G WHY 0 WHAT 4 WHERE 8 WHEN r N<N 0.

A. PROCEDURE

S N s TO SUPPORT /0VERVIEW N. BCAP \\ 'NN N N N N N_ x N 'N .x N N N. N N N _,-...- _._,-._. --__- _ _ ___.__-.._ _ - 1 _,-,

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DEVELOPMENT RESULTS e BCAP Q.A. PLAN APPROVED JULY 16, 1984 e 12 Q.A. SPECIAL INSTRUCTIONS ISSUED AUGUST 7, 1984 - 3 0.A. SPECIAL INSTRUCTIONS IN PROGRESS l i i 1 i i (0059B)

BCAP DOCUMENT REVIEWS REVIEWED AND CONCURRED IN: 4 BCAP TASK FORCE PLANS 16 BCAP TASK FORCE PROCEDURES 't =.. l (0059B)

S AUDIT /SURVEILIANCE APPROACH e e 8 MATRIX OF REQUIREMENTS S SCHEDULE 9 l l 6

BCAP (XMIIMENT MATRIX i Item Comitment June 84 Plans Procedures Proc. Doc. OA Overview CSR RPSR RSCAP BCAP OASI Coments i 102 Control documents will IV-1 II 3 of 12 22-3.5 07 l identify what is to (Pg. 6) Para. II IIE 4.4.2 15 be inspected or reviewed II 2&4 (Pg. 3) (Pg. 4) specify how the inspection (Pg. 9) or review is to be conducted and identify the inspection acceptance j criteria and requisite quality documentation. I 103 BCAP activities will II (Pg. 5) 22-3.5 06 ~ be controlled through IV-1 II (pg. 8) 2.8 3 of 12 IIC 24-3.3 the use of written II (pg. 9) 2.0 (Pg. 3) i procedures, intro II (pg. 6) 4. checklists approved by the BCAP Director with QA concurrence. j 104 Persons perfonning BCAP IV-1 II (Pg. 9 inspection criteries will ES-1 7 of 12 08 04 be trained, qualified and II (Pg. 8) 24-3.3 certified IAW ANSI N45.2.6 (1978) Reg. Guide 1.58. l. 2 4 l 4 3 e

AUDIT AND SURVEILLANCE SCHEDulF WEEK 0F WEEK OF WEEK 0F WEEK 0F ELEMENT PROCEDURE (S) SEPT. 17 SEPT. 24 0CT. 1 OCT. 8 CSR 5 AUDIT AUDIT AUDIT 1 AREA 1 AREA 1 AREA AUDIT 2 AREAS SURVEILLANCE SURVEILLANCE SURd I LL ANCE 3 AREAS 4 AREAS 4 AREAS I RPSR 3 AUDIT SURVEILLANCE SURVEILLANCE 3 AREAS 3 AREAS 3 AREAS RSCAP 1 AUDIT SURVEILLANCE SURVEILLANCE 1 AREA 1 AREA 1 AREA ADMIN. 7 AUDIT 7 AREAS l t l (0059B) I

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~ CHARTER l SERVE AS AN INDEPENDENT EXPERT OVERVIEW GROUP TO ASSURE THAT THE BCAP MEETS ITS OBJECTIVES BY: 4 REVIEWING ALL ELEMENTS OF THE PROGRAM a

• REVIEWING ALL PROCEDURES AND IMPLEMENTING INSTRUCTION l
• REVIEWING THE BCAP QUALITY ASSURANCE / CONTROL i

PROGRAM l

• CONDUCT OF AUDITS
• INSPECTIONS
• MONITORING THE PROGRESS OF ALL SUPPORT PERSONNEL j
• REVIEWING THE RESULTS OF EACH ELEMENT OF THE i

PROGRAM ON AN ON-GOING BASIS l l l b

~. j PROTOCOL i COMMUNICATIONS / METHOD OF OPERATION CORRESPONDENCE WILL BE PROVIDED TO EDISON AND NRC SIMULTANEOUSLY - GENERAL CORRESPONDENCE - MONTHLY REPORTS - INTERIM & FINAL AUDIT REPORTS - FINAL PROGRAM REPORT - OBSERVATIONS & FINDINGS l ERC ASSURED PROMPT ACCESS TO INFORMATION AND l ACTIVITIES REQUIRED TO FULFILL OUR ROLE l ERC WILL KEEP RECORDS OF ALL MEETINGS WITH EDISON INCLUDING A STATEMENT OF PURPOSE i - THESE RECORDS ARE AVAILABLE FOR NRC REVIEW i MONTHLY MEETINGS WITH EDISON AND NRC a - OPEN TO THE PUBLIC - MINUTES WILL BE PUBLISHED l \\

EVALUATION TESEATCH COWPOWATION CECO e Tom Maiman I ERC Project Manager John Hansel Ass't. Project Manager Bob Ham Quality Administration Assurance Catherine Ed Cocoros % mpson l I I I I I'#I' "' "^ OA 8 Audits nd P pi g St u ural ck Petrick Bob Laney J hn Hansel Wayne Chase Bob Ham CSR f h Bob Ham l P L RCSAP METHODOLOGY m i Ed Cocoros N 1 f RPSR Wayne Chase Records Mgm't. Catherine Thompson

I ~ i 1 REVIEWS a l ERC WILL CONDUCT, A REVIEW OF ALL PLANS, PROCEDURES, .I CHECKLISTS, AND ANY OTHER DOCUMENTS GENERATED TO DEFINE ACTIVITY FOR BCAP. COMMENTS WILL BE l CATEGORIZED SUCH THAT VISIBILITY IS PLACED ON THOSE COMMENTS JUDGED TO BE CRITICAL FOR A SUCCESSFUL l PROGRAM. I I l l l

~. AUDITS l RIGOROUS AUDITS WILL BE PERFORMED IN EACH OF FIVE l AREAS TO ASSESS THE IMPLEMENTATION OF BCAP. THE FIVE l AREAS ARE: I

• ADMINISTRATIVE
• QUALITY ASSURANCE
• CSR
• RPSR
• RSCAP i

i THESE AUDITS WILL BE DEVELOPED, CONDUCTED, AND { REPORTED BACK TO CECO USING STANDARD AUDITING l TECHNIQUES IN ACCORDANCE WITH ANSI 45.2.23. EACH j AUDIT WILL BE LED BY A CERTIFIED LEAD AUDITOR. i 1 L-

~ i I SURVEILLANCES PROGRAMMATIC SURVEILLANCES WILL BE CONDUCTED TO ENSURE THAT THE DEFINED PROGRAM IS ADEQUATE AND BEING IMPLEMENTED CORRECTLY. TECHNICAL SURVEILLANCES WILL BE CONDUCTED TO ASSESS THE q i CORRECTNESS OF THE TECHNICAL APPROACH IN EACH OF THE FOUR TECHNICAL DISCIPLINES, E.G., HVAC, ELECTRICAL, j MECHANICAllPIPING, AND CIVIIJSTRUCTURAL. i l

l ~. i l i INSPECTIONS REINSPECTIONS WILL BE OVERVIEWED BY THE ERC l PERSONNEL RESPONSIBLE FOR THE PARTICULAR ELEMENT CATEGORY WITH WHICH THE REINSPECTION IS ASSOCIATED, E.G., CSR, RSCAP, RPSR. MOST REINSPECTIONS WILL BE PERFORMED IN THE CSR ELEMENT. IN ADDITION TO THE j REINSPECTION AUDITS, SAMPLE REINSPECTIONS ARE l ANTICIPATED AS INDEPENDENT VERIFICATION. i i'

~. ONGQING OVERVIEWS I l IN ADDITION TO THE SPECIFICALLY LISTED METHODS OF l OVERVIEWING BCAP, ERC WILL CONT!NUALLY MONITOR BCAP SCHEDULES AND PROGRESS OF THE PROGRAM. THE MONITORING WILL INCLUDE INTERVIEWS WITH BCAP l PERSONNEL PERFORMING ACTIVITIES IN ACCORDANCE WITH l BCAP PROCEDURES. EACH ERC MEMBER WILL HAVE HIS/HER l OWN PERSONAL LOG BOOK TO DOCUMENT EACH DAY'S 1 ACTIVITIES FOR RECORD PURPOSES. COPIES OF THESE DAILY SHEETS WILL BE FILED IN THE ERC FILE ON-SITE AND IN THE OAK RIDGE OFFICE. i i

~ ~. i l OBSERVATIONS l IN ADDITION TO DOCUMENTING AUDIT FINDINGS, ERC WILL DOCUMENT ALL OBSERVATIONS THAT REQUIRE FURTHER EVALUATION TO DETERMINE ACCEPTABILITY OF THE NOTED PRACTICE. THESE OBSERVATIONS WILL BE SERIALIZED AND SUBMITTED TO CECO FOR RESPONSE. SATISFACTORY RESPONSES WILL RESULT IN A CLOSING OF THE OBSERVATION. UNSATISFACTORY RESPONSES WILL RESULT IN i l AN ESCALATION OF THE OBSERVATION TO A REQUEST FOR l CORRECTIVE ACTION (RCA). THIS RCA WILL ALSO RECEIVE A i UNIQUE SERIALIZATION AND BE SUBMITTED TO THE BCAP l DIRECTOR FOR RESOLUTION. i i I

~ I BCAP REVIEW

SUMMARY

i WEEK OF

SUMMARY

JUNE 11 BCAP POLICY DOCUMENT (LEVEL 1) JULY 9 a) BCAP OVERVIEW DOCUMENT (LEVEL 2) b) CSR PLAN (LEVEL 3) c) RPSR PLAN (LEVEL 3) d) RSCAP PLAN (LEVEL 3) ) e) BCAP QA PLAN (PRELIMINARY) JULY 23 a) PRELIMINARY BCAP PROCEDURES (f.EVEL 4) b) INTERVIEWS WITH CSR, RPSR, AND RSCAP TEAMS FOR RESULTS OF PROCEDURE WALK-THROUGHS JULY 30 a) REVIEW PRELIMINARY BCAP PROCEDURES b) REVIEWED FINAL BCAP QA PLAN AUGUST 6 a) REVIEWED DRAFTS OF BCAP PROCEDURES AND PROVIDED COMMENTS TO CECO i l l l 1 1 1

l l BCAP REVIEW

SUMMARY

l (CONTINUED) l i AUGUST 20 a) REVIEWED FINAL BCAP PROCEDURES: BCAP-01 BCAP-20 l BCAP-02 BCAP-21 BCAP-04 BCAP-22 BCAP-06 BCAP-23 i BCAP-07 BCAP-24 l BCAP-08 BCAP-60 b) MET WITH BCAP PERSONNEL TO PROVIDE INFORMAL COMMENTS WITH NRC IN ATTENDANCE l AUGUST 27 a) CATEGORIZED COMMENTS ON BCAP PROCEDURES LISTED j ABOVE AND PROVIDED FORMAL COMMENTS TO CECO i b) REVIEWED CECO RESPONSE AND AGREED WITH THEIR POSITION SUBJECT TO INCORPORATION AND RETAINING OF PERSONNEL c) PERFORMED A SURVEILLANCE OF

1) RPSR

2) BCAP-08 IMPLEMENTATION j

3) BCAP-01 IMPLEMENTATION i

d) REVIEW DRAFT CHECKLISTS FOR CSR:

1) CONCRETE PLACEMENT

2) SMALL BORE PIPING

3) ELECTRICAL CONDUIT 4)'HVAC DUCT WORK

OPEN ISSUES / CONCERNS RSCAP

• AS CURRENTLY WRITTEN HAS AN OBJECTIVE TO ASSURE THAT PREVIOUS COMMITMENTS HAVE BEEN ADEQUATELY IMPLEMENTED AND DOCUMENTED
• WE RECOMMEND THAT A REVIEW BE CONDUCTED TO DETERMINE IF THESE COMMITMENTS ARE ADEQUATE TO PREVENT RECURRENCE OF THE PROBLEM OR CONCERN RPSR
• IS DESIGNED TO ASSURE THAT CONTRACTOR PROCEDURES ADDRESS ALL I

APPLICABLE DESIGN AND REGULATORY REQUIREMENTS

• RPSR DOES NOT REQUIRE A REVIEW AGAINST FSAR REQUIREMENTS /

COMMITMENTS i GENERAL

• INCONSISTENCY BETWEEN VARIOUS BCAP DOCUMENTS CONCERNING BASELINE DATES

- JUNE 1 VS JUNE 30 l

• DUE TO REVISIONS THERE ARE MINOR INCONSISTENCIES IN BCAP DOCUMENTS

- A REVIEW NEEDS TO BE CONDUCTED AND CORRECTIONS MADE TO ASSURE CONSISTENCY l -l NOTE: EACH OF THESE CONCERNS WERE DISCUSSED WITH EDISON ON AUGUST 29,1984 AND THEY HAVE AGREED TO TAKE APPROPRIATE j ACTION. i

~ ITEMS DISCUS 3RD AT NRC/ Ceco /ERC MEETING SEPTEMBER 6, 1984 9:00 A.M. \\ 9 Will BCAP address the findings of the recent INFO evaluation? A. The BCAP will not explicitly address the INFO findings, in that these findings will be addressed under separately established l corrective action programs designed to specifically address the INFO findings. However, the execution of BCAP will gg,be limited from reviewing areas identified by INPO findings. g. Is BCAP a closed program? Is the scope predetermined or will it be expanded as problems are identified? j A. The BCAP is a closed program. If problems are identified by the j BCAP, specific corrective action programs separate from BCAP will be I ] formulated to address these concerns. l 1 9 The BCAP recently stopped work on the RSCAP element of at BCAP. Please give the reasons for the work stoppage. A. The 1500 had comumented on the scope of the RsCAP. Until this j comument was addressed to the IBOG's satisfaction, CsCo temporarily discontinued work on RSCAP. i f g. What problems have been identified to date by BCAP7 j A. No problems with construction have been identified to date, in that BCAP has not yet gone beyond the planning and program development j stage. 4 g. Will Caco 94 review the readiness of the Csa prior to the start of j inspections? h A. Caco BCAP 94 will perform this review. l g. Will the 1500 have their own inspection personnel? p I A. 1500 will have inspection personnel as they deem necessary to 1 perform their function. It is currently estimated that there will l be three inspectors certified as Level III in accordance with ANSI M45.2-6. This number is subject to change based on the level of i overinspections 1500 will require to assure itself that BCAP inspections are being properly performed. l g. Does 1900 intend to do inspections prior to, concurrent with, or after the Csa inspections? ( A. tile 1900 expects to perform inspections both concurrent with and after Csa inspections. i (0294J) I

9 Now will Caco and the 1500 handle the past and ongoing work to procedures for which tha 1800 has mandatory comments? 1 A. 150G believes two options are available, depending on the nature of ) the comment and the extent to which continuing work is affacted by i the comment. On a case by case basis, it will be decided whether work can continue or work must be halted pending resolution of the i comment. l 9 ' Mas 1500 reviewed any comments on the BCAP which might have been provided by Ceco's consultants? A. 1500 has not seen any such comments. 1300 would prefer to maintain ) en indepenCant view of the SCAP Program. 9 Will BCAP review hardware for which discrepancies have been i previously identified and which are being addressed by ongoing programs (e.g. small bore piping miniman wall concerns and material j traceability)? By doing so, will BCAP bias the results of the CSR by looking at items previously scrutinized by Caco, the contractors, and the NRC? A. The CsR will select items from populations in two ways, one way l selects items at random from the population, ensuring all items in t the population have an equal probability of being selected for inspection. This will ensure that no class of items are excluded j from the sample. The other method of sample selection is based upon j engineering judgement, as discussed in the BCAP program document. I i The NRC discussed with CBCo and the 1500 several aspects of the training { program applicable to SCAP. Additional discussions regarding this subject will be held on the site between Caco and the NRC BCAP inspector. MRC has reviewed the caco response to NRC commentu on the BCAP. On the j basis of this review, the NRC believes that the SCAP activities may proceed. l Three remaining open items exist. The NRC will continue to review Ceco's i response to NRC comments 1 and III-3. Also, the NRC will interpret the "may" l as a "will" in the second line of the second paragraph of Ceco's response to l j NRC comment II-5. l j The NRC stated they expected to discuss in future meetings significant 1 construction discrepancies identified by BCAP as well as design-significant j discrepancies. I In conclusion, the NRC reiterated their belief that the SCAP is an i important effort. l i i (0294J)

1 l M POSITION OltGANIZATION R. A. Gardner Reactor Inspector Region III, NRC R. F. Warnick Chief, Branch 1 Region III, NRC C. E. Morelius Director, Reactor Projects Region III, NRC J. G. Keppler Regional Administrator Region III, NRC W. L. Porney Chief, Section, 1A Region III, NRC R. D. Schulz Sr. Resident - Braidwood Region III, NRC L. G. McGregor S.R.I. Braidwood Region III, NRC R. J. Lauer Attorney Isham, Lincoln & Beal E. D. Swartz Nuclear Licensing Admin. CECO J. G. Toscas Admin. Assist., Nuclear Info Ceco /Comm. Service C. W. Schroeder Proj. Lic. & Compliance Supt. Ceco A. Scaccia Off Site Emer. Planner CECO D. L. Leone Projects Eng. Mgr. - BY & BR CECO G. F. Marcus Director of Quality Assurance Ceco B. R. Shelton Projects Eng. Manager CECO G. M. Orlov Asst. Director BCAP CECO R. L. Byers Asst. Director BCAP CECO K. T. Kostal Project Director Braidwood S&L L. O. De1 George Asst. Vice President Ceco R. E. Ham Asst. Project Manager ERC J. L. Hansel 1500 Project Manager ERC N. P. Smith General Supervisor - QA Ceco E. E. Pittpatrick Asst. Manager QA CECO N. N. Kaushal Director, BCAP CECO M. J. Wallace Asst. Mgr. of Projects & Proj. CECO Manager Braidwood T. J. Maiman Manager of Projects Ceco J. Strasma Public Affairs Officer NRC (0294J)

Braidwood Station Braidwood Construction Assessment Program Program Progress Report Report Period August 1 - August 31, 1984 1. SUpWEARY STATUS This is the second monthly Progress Report on the Braidwood construction Assessment Program (BCAP). This report covers the period from August i through August 31, 1984. The Braidwood Construction Assessment Program was docketed with the Office of the Nuclear Regulatory Commission, Region III on June 22, 1984. Since that date four (4) primary plans have been prepared and approved. The four plans are the BCAP Overview Plan, the construction Sample Reinspection (CSR) Plan, the Reverification of Procedures to Specification Requirements (RPSR) Plan, and the Review of Significant Corrective Action Programs (RSCAP) Plan. Sixteen (out of a total of seventeen) BCAP procedures have been prepared and are approved. The remaining procedure (BCAP-25 Evaluation of Results) has been drafted and is in the process of review and approval. Preparatory research and documentation gathering has begun to support the 1 CSR, RPSR, and RSCAP elements of the BCAP. As of August 31, 1984 the manpower assigned to the BCAP effort has risen to seventy-eight personnel. Office and clerical facilities have been established at the Braidwood Station to support the anticipated total BCAP workforce of eighty-two. i 0256J

II. SCHEDULE ANALYSIS I The overall BCAP effort is approximately three (3) weeks behind l schedule. Delays in the completion of BCAP procedures have resulted in corresponding delays in the inspector training, preparation of reinspection & document review packages, and therefore, the performance of the reinspections. Detailed planning for the total effort to completion, is in progress. 4 l III. r 9E C L AND BOUIPMENT STATUS Actual BCAP manpower totaled seventy-eight (~18) as of August 31. 1984. 1 The planned manpower was anticipated to have been eighty-two (82) at this 4 l time. This difference is mostly attributable to scheduled vacation ti:.e t' taken this week. Inspection personnel are now on site in preparation for the start of reinspections in early September. I i I office equipment and clerical support equipment have been installed and l l are in operation. l The computerized MAPPER system for tracking verification packages has t'een installed and personnel have been trained in its use. At the current time there are no delays expected due to i l equipment. I k 1 l I i i 5 0256J .--y ,,,.-n,-,m.-- --c-m v-n-- --n,.,n,, .r-r, , -,,- +,, - - -, - -, -. mwn,-<r, n- -~

IV. BCAP El.lOWOIT STATUS A. CSR STATUS During August, five of the six CSR procedures were issued and are now being used by the engineers in selecting samples, writing checklists and instructions and assembling the packages to be used by the inspectors. Three (BCAP-20, 21 and 22) of the five issued procedures are being revised to incorporate Independent Expert overview Group (1800) and QA comments. Draft procedure CSR-25 (Evaluation of Results) has also been revised and is ready for final internal review. A tentative list of construction categories has been established for the purpose of selecting a re-inspection sample from each category. The major activities currently in progress are the selection of samples from contractor tabulations of safety related work completed inspected and QA accepted, writing checklists and instructions for each construction category for both the hardware reinspection and document review phases, and assembling the documents and required references for the sample packages being assembled. During this period, the procedure for training and certification of inspection personnel was also prepared and implemented. The training and certification of level III and level II inspection personnel is expected to be completed in time to support start of \\ inspections in the first week of September. 0256J

-= a Major activities to be completed in September will be: Y I 1. Issuing CSR-25 2. Updating all procedures i i 3. Continuing the development of all the population checklists and instructions 4. Selecting the engineering judgement portions of the samples 4 B. RPSR Status During August 1984, the RPSR group was primarily involved in updating the RPSR Plan and procedures, preparing tentative 1 checklists of construction requirements contained in Sargent and Lundy specifications, and becoming familiar with pertinent documentation. The plan was changed to reflect the three procedures i i that were developed to govern RPSR activities and to include the review of installation and inspection procedures against the regulatory commitments in the FSAR. I.essons learned during i j walkthroughs and the added requirement of the review against FSAR commitments were incorporated in the three RPSR procedures BCAP 41, 42, and 43. Tentative checklists were prepared by each Lead l Discipline Engineer for experience and standardization. The FSAR, contractor procedures, and applicable codes were perused for fastliarizatia. The staff of the RPSR Hlement was increased to the l planned number of seven during the month, one more structural i l l j engineer will be added in September to support the schedule. '0256J

4 c. RSCAP Status l All RSCAP personnel have received required training. The review of the five programs listed below was initiated and has progressed as shown below. a. QCSsa - 62% b. Safety Related Pipe Supports - 50% c. NSSS Component Supports - 39% d. Electrical Installation Documentation Review - 21% e. Quality control Inspector Reinspection - 21% The checklists required by BCAP-60 are being developed and approved for the review of those programs. Support from other Ceco Departments and site contractors has been good. The progress on the RSCAP element has been satisfactory. 0256J l

V. PRost.ItMS/DISCRRPANCY FINDINGS A. Implementation Problems No significant problems have been encountered to date. Establishment of the BCAP organization and provision of logistical support to BCAP have proceeded smoothly. The minor delays in schedule have been primarily due to the effort required being greater than aaticipated. 8. Maior Discrenancy Pindings None to date. VI. NBC0ff9ENDATIONS No specific recommendations are offered at this time. 1 N N,kA(14,\\4.b. W. N. Naushal Director Braidwood Construction Assessment Program j telR/js 02S4J}}