ML20101E406

Forwards Changes to Const Assessment Program,Per & Discussions W/Nrc

ML20101E406
Person / Time
Site:	Braidwood
Issue date:	12/13/1984
From:	Danni Smith COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
9503N, NUDOCS 8412260238
Download: ML20101E406 (4)

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Commonwealth Edison-4>

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) On) First National Plaza Chic. go, Illinois e-b Address Reply 13: Past Office Box 767 j 03ITY ROUTIg(i

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j Chicsgo, Illinois 60690 89 #kM4 ypt E

December 13, 1984 HLQWL ~

~ Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Braidwood Station Units 1 and 2 Braidwood Construction Assessment Program NRC Docket-Nos.-50-456/457-References (a):

J. J. O'Connor letter to J. G. Keppler dated Junt. 22, 1984 (b):

J. G. Keppler letter to J. J. O'Connor y

dated July 27, 1984 (c):

J. J. O'Connor letter to J. G. Keppler dated August 30, 1984 (d):

J. G. Keppler letter to Cordell Reed dated September 14, 1984

Dear Mr. Keppler:

Reference (a) transmitted to you the scope document for the Braidwood Construction Assessment Program (BCAP). In Reference (b),

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you provided comments upon the program which were addressed in Reference (c). This input, along with discussions with members of your staff and experience gained in implementing BCAP, necessitate a number of changes to the scope document. Those changes are contained in the Attachment to this letter.

If you or your staff have any questions regarding this matter, please contact this office.

h truly

cars, UduulfA David H. Smith Nuclear Licensing Administrator l

cc: J. J. O'Connor 9503N DEC 141so4 /

8412260238 841213 PDR ADOCK 05000456 p.

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j Attachment 1

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I Errata and' Changes;to the i

8RAIDWOOD CONSTRUCTION ASSESS >ENT PROGRAM (BCAP)

Program Document.of. June 1984 15

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i age II-1.--1In'ths second.line, change." June 1" to~" June 30",

P correcting the CSR sample date to be consistent with that used in the document.for the RPSR (page II-8) element cutoff date.

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Page II-1. win Item A,' first' line, change "... a'significant sample

' " ' to "... a ~ sufficient sample...". This corrects an editorial error. in the description of. the size of the CSR program sample and.

imakes'the detailed section read as does the Executive Summary-(page A

ES-1)..

-3.)~2Page4II-5. In Item 2,, third paragraph, change the;first. sentence to delete "and the. Architect / Engineer" which willl delete the requirement for that organization to determine'the root cause. The M

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4 root.cause is generally.not determinable by the Architect / Engineer

'since its determination.would;likely. require specific contractor and

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CECO investigation. The BCAP. Task Force is currently required to.

perform this identification which should be sufficient. Procedures

'for-BCAP.will have the Architect / Engineer comment on the root cause rather than attempt its identification.

M 'Page II-5-through II-8.

Change the heading of Item ~2 to read "2.

CSR Results Evaluation and Sample Expansion Criteria". Replace the.

• A Item 2 paragraphs '4 through 8 (from " Based on the identification..."

to' the end.of the section=on page II-6 and the first paragraph on page II-8),' including. Table'.1, with the following:

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" Work in a construction category is considered acceptable if no p

design significant discrepancy is found in the initial' sample.

"If a design significant discrepancy is identified in the

-initial sample', an additional sample will be chosen.

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-Inspections of all attributes as inspected in the initial

. sample will be performed for this expansion sample.

"The results of this expansion sample will determine whether

.the initial design-significant discrepancy is an isolated

. case.. If it is determined to be an isolated case, then no n

additional inspections will be performed.

If, however, an additional. design-significant discrepancy is identified in the 7-

-expansion sample, then a comparison of the discrepancies for their root"cause (or causes) will be performed. If the discrepancies have similar root causes, then 100% of the items potentially affected by the root cause will be reinspected.

..These inspections will be of the type sufficient to identify discrepancies similar in nature to those identified in the previous-samples.

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a "If these: design-significant discrepancies have unrelated root:

causes, then an edditional sample will be reinspected for all

. attributes-initially inspected -to determine '.if either of-these.

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discrepancies is an isolated' case.or is representative of a s.

. programmatic. discrepancy.1-If these cases ~cannot be. determined 4

to be? isolated, then 1005'of the accessible items in the.

. population will be' reinspected for all initially inspected-J

_ attributes."

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This. revised-~ evaluation criteria ~ is changed per Reference (c) to an MtC comment onlpage

II-5.pThis also incorporates the change of r a wording to the;1ast' paragraph, first sentence, as discussed in the l

Jmeeting of September:6,'.1984 and documentedzin the subsequent-g

_C (meeting minutes ~ of Septenber 13, 1984. TThe wording ~is the same as that in these. documents, except that reference to a discrepancy.

being processed;as an Non-Conformance Report has been removed since it'already appears in the' Program' document'on~page II-5 in the

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-subject item.-

' 5...Page III-2. Delete the Figure-1 organizational chart's block.at the

' lower right. titled " Commonwealth Edison Company Designated Representative." This-position is no longer necessary considering

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Lthe, establishment of the " Protocol Governing Communications between.

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Commonwealth Edison Company and Evaluation Research Corporation b

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(ERC)" per Reference-(c) as approved by-Reference (d).

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6. ~ ;Page IV-2.

Change the last. word from " objective" to " objectives" to correct a typographical error.

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Page V-1 and V-2.

Add "and to the WC" to the end of sentences that ihave:. "a copy to the President and Chairman uf the Board of

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Commonwealth Edison." (last paragraph.on;page'V-1 and th hd full 4

paragraph on page V-2).

This char.ge requires the forwarding of -

periodic ~and a final report by the Independent Expert Overview Group to mC in accordance with Reference (c).

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.Page V-2.

Delete.in the first full paragraph on this page "and will communicate with Commonwealth Edison through a designated f

Commonwealth Edison representative". The lines of communication are

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defined by the protocol agreement and other-specific references such

as the sentence that follows in the BCAP Program document.

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Page V-2. - In the second full ~ paragraph, change " submitted to the

designated-Commonwealth Edison representative" to " submitted to the

-Commonwealth Edison Manager of Projects." This recognizes the elimination of the designated representative.

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10. :Page:V-2. In the second full paragraph, change the last sentence, to read "All such observations or discrepancies will be..

resolved...". This avoids any inference that an observation could be left open1 and also resolves 'a comment by ERC- (letter of July 2, 1984 from'J.L. Hansel to T. Maiman).

-11. :Page A-1.

In the second paragraph, change " Appendix C" to " Appendix B" to correct an editorial error.

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