ML20115C695

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Forwards Monthly Minutes/Rept of 850214 Meeting Re Status of Const Assessment Program.Viewgraphs Encl
ML20115C695
Person / Time
Site: Braidwood  
Issue date: 03/12/1985
From: Danni Smith
COMMONWEALTH EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
9856N, NUDOCS 8504180508
Download: ML20115C695 (48)


Text

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Commonwealth Edison

'g one First National Piar;. Chicago, Hlanors o

Address Reply to: Post Office Box 767 Chicago Illinois 60690

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Marcn 12, 1985 9

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Mr. James G. Keppler n

Regional Administrator - Region III El U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Braidwood Station Units 1 & 2 Braidwood Construction Assessment Program Monthly Meeting Minutes / Monthly Report Docket No. 50-456 and 50-457

Dear Mr. Keppler:

The sixth open briefing on the status of the BCAP effort was provided to the NRC on February 14, 1985 at the 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 March 14, 1985 at the Mazon EOF.

Also forwarded herewith for your information is the BCAP Director's Progress Report for the month of January, 1985.

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

T hely truly ycfurs, l

t David H. Smith Nuclear Licensing Administrator Attachments cc:

NRC Resident Inspector - Braidwood NRC BCAP Inspector - Braidwood John Hansel - ERC N. N. Kaushal - CECO

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Meeting Sunuaary BCAP NRC/ CECO /ERC Monthly Meeting j

February 14, 1985 9:00 a.m.

NRC Region III Office Glen Ellyn, Illinois The meeting was opened with a brief statement by R. F. Warnick of the NRC

. Region III giving the purpose for the meeting, that is, to discuss BCAP, it's progress, and the Independent Expert Overview Group's (IEOG) review of the BCAP.

Mr. Warnick also. stated that upon completion of the presentation by CECO and the IBOG, the NRC would respond to questions from the public-in attendance.

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

I.

Introduction Presented by.the Braidwood Project Manager to provide the major topics of the presentation (see Enclosure 1).

II.

BCAP Task Force-Presented by the BCAP Director to provide the BCAP achievements for the month of October,(see Enclosure 2).

III.-

Discrepancy Evaluation Presented by the Sargent & Lundy Project Director to provide Sargent & Lundy's status of work (see Enclosure 3).

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IV.

Quality Assurance Presented by the General Supervisor of Quality Assurance to describe the overview activities of'the Ceco BCAP QR group'(see

Enclosure:

4).

V.

Special Topics

{;

Presented by the Braidwood Project Manager and the BCAP. Director to cover the-" Midpoint'Look" at CSR Activity, Processing BCAP Identified Discrepancies and Engineering. Judgement Sample

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Selection (See; Enclosure 5).

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IEOG Progress Report Presented by the Project Manager of.the IEOG to describe the overview activities of the IBOG (see Enclosure 6).

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Additional items discussed-during the meeting are included in....The attendance for the meeting is provided in Enclosure 8.

.The

- meeting adjourned at'11:15 a.m.

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Page 1 of 1 e

BRAIDWOOD CONSTRUCTION ASSESSMENT PROGRAM (BCAED MONTHLY NRC STAFF BRIEFING FEBRUARY 14, 1985 I.

INTRODUCTION MIKE WALLACE II.

BCAP TASK FORCE NINU KAUSHAL III.

DISCREPANCY EVALUATION KEN K0STAL 4 -

IV.

QUALITY ASSURANCE NEIL SMITH f

V.

SPECIAL TOPICS MIKE WALLACE/

NINU KAUSHAL A.

" MIDPOINT LOOK" AT CSR ACTIVITY B.

PROCESSING BCAP IDENTIFIED DISCREPANCIES C-ENGINEERING JUDGEMENT SAMPLE-SELECTION VI.

INDEPENDENT EXPERT.0VERVIEW GROUP-JOHN HANSEL-

Page 1 of 5 4

-BRAIDWOOD CONSTRUCTION ASSESSMENT PROGRAM (BCAP)

MONTHLY BRIEFING PRESENTED TO REGIONAL OFFICE REGION III U. S. NUCLEAR REGULATORY COMMISSION N. N. KAUSHAL BCAP DIRECTOR FEBRUARY 14, 1985

Ehclosure 2 CSR STATUS COMPLETED TOTAL-IDENTIFICATION OF CONSTRUCTION CATEGORIES 30 30 DESCRIPTION OF POPULATIONS 30 30 IDENTIFICATION OF ITEMS IN POPULATIONS 18 30 RAND 0M PORTION SELECTION 16 30 ENGINEERING JUDGEMENT PORTION SELECTION 11 30 REINSPECTION CHECKLISTS 21 28 VERIFICATION PACKAGES 1,336 2,716" REINSPECTIONS 969 2,716" DOCUMENTATION REVIEW CHECKLISTS 18 30 DOCUMENTATION REVIEW PACKAGES 1,013 2,527" DOCUMENTATION REVIEWS 364 2,527' APPR0XIMATE, CURRENT ESTIMATE l

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RPSR STATUS IDENTIFICATION OF CONTRACTOR PROCEDURES IS COMPLETE, TOTAL 0F 500 PROCEDURES IDENTIFIED (DECEMBER, 1984)

IDENTIFICATION OF CONSTRUCTION REQUIREMENTS IN FSAR

~ COMPLETED (0CTOBER, 1984)

IDENTIFICATION OF PERSONNEL QUALIFICATION AND CERTIFICATION REQUIREMENTS COMPLETED (NOVEMBER, 1984)

IDENTIFICATION OF CONSTRUCTION REQUIREMENTS IN APPLICABLE SPECIFICATIONS IS COMPLETE (JANUARY, 1985)

PREPARATION OF CHECKLISTS AND REVIEW 0F PROCEDURES INITIATED.

COMPARIS0N OF CHECKLISTS AGAINST PROCEDURES COMPLETED FOR ONE CONTRACTOR (1134D)

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RSCAP STATUS i

ALL SCAPS ARE UNDER REVIEW (N0VEMBER, 1984)

QCSSR FINAL REPORT DRAFTED AND UNDER REVIEW (JANUARY, 1985)

SAFETY-RELATED PIPE SUPPORTS REPORT IN DRAFT STAGE (JANUARY, 1985)

REINSPECTION OF SAFETY-RELATED MECHANICAL EQUIPMENT DOCUMENTATION AND REPORT PREPARATION IN PROGRESS ELECTRICAL INSTALLATION DOCUMENTATION REVIEW DOCUMENTATION AND REPORT PREPARATION IN PROGRESS SEVEN (7) OBSERVATIONS IDENTIFIED DURING LAST MONTH (TOTAL TO DATE - 17)

(1304D)

BCAP MANPOWER i

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til JUN AUG OCT DEC FEB APR JUN 1984 1985

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g Page 1 of 8 CSR REINSPECTION DISCREPANCIES BY CONTRACTOR CONTRACTOR POPULATION RECEIVED COMPLET_ED COMSTOCK CONDUIT 171 160 CONDUITHANG$RS 32 -

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NEWBERG-CONCRETE PLACEMENT 74 38 543 413 S

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Page 2 of 8 CSRDISCREPANCIESBY'CLisSIFICATION CLASSIFICATION RECEIVED COT 1PLETED WELDING

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ORGANIZATION / PERSONNEL 1

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.9 TWO INSPECTORS HAVE BEEN ADPED 0

0/0 GROUP SUPERVISOR HAS BEEN REASSIGNED AS ASSISTANT TO GENERAL SUPERVISOR Q.A. FOR SPECIAL PROJECTS I

e THE ASSISTANT 0/0. GROUP SUPERVISOR HAS BEEN DESIGNATED 0/0 GROUP SUPERVISOR

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Enclosure k Page 4 of-10 f.

l HCAP OUALITY ASSURANCE EXPERIENCE IEVElS (AdlERAGF YRS. PER PFRSON)

ENGINEERS / SPECIALISTS INSPECTORS TOTAL EXPERIENCE 21.5 14.9 NUCLEAR EXPERIENCE 14.2 6.7 QUALITY ASSURANCE / QUALITY 5.6 12.1-CONTROL EXPERIENCE i

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]l0CUMENT REVIEWS (JANUARY)

REVISIONS TO POLICY / PLANS 1

REVISIONS TO PROCEDURES / INSTRUCTIONS 8

REINSPECTION CHECKLISTS / INSTRUCTIONS 34 INSPECTOR CERTIFICATION PACKAGES 9

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O.A. OVERINSPECTION/ OVERVIEW C.

9-COMMENDED INSPECTION ON 12/27/84 9

PERFORMED OVERINSPECTION IN 14 POPULATIONS 9

COMPLETED 66 OF 80 (82%) INSPECTIONS PLANNED TO DATE 1

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SUMMARY

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Page 1 of 8

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" MIDPOINT LOOK"- T CSR ACTIVITY

-A.

OBSERVATIONS 0N CSR ACTIVITY NRC CAT EXIT JANUARY 18, 1985 e

INDEPENDENT EXPERT OVERVIEW-GROUP 0BSERVATIONS k

4, k

hic 3bsuEe5 Page 2 of 8

" MIDPOINT LOOK" AT CSR ACTIVITY p

1B.

ACTIONS TAKEN SUSPEND INSPECTIONS JANUARY 23, 1985 REVIEWED INPUT ON COMPLETED INSPECTIONS IDENTIFIED AREAS FOR ADDITIONAL EVALUATION MECHANICAL PIPE SUPPORTS ELECTRICAL CONDUIT SUPPORTS c

CONCRETE PLACEMENT DEVELOP ACTION PLAN FOR EACH AREA

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" MIDPOINT l00K" AT CSR-ACTIVITY C.

STATUS MECHANICAL PIPE SUPPORTS REINSPECTION OF-CERTAIN ATTRIBUTES i

FEEDBACK SESSION WITH INSPECTORS RESUMED INSPECTIONS:

FEBRUARY 1, 1985 ELECTRICAL CONDUIT HANGERS REINSPECTION OF CERTAIN ATTRIBUTES i

REVISION TO CHECKLIST FEEDBACK SESSION WITH INSPECTORS RESUMED INSPECTIONS:

FEBRUARY 8, 1985

E5 closure 5 Page h of 8 l

" MIDPOINT 100K" AT CSR ACTIVITY j

C.

STATUS CONCRETE PLACEMENT.

ENGINEERING EVALUATING SCOPE OF REINSPECTION REVISING CHECKLIST HOLD FEEDBACK SESSION WITH INSPECTORS BEGIN REINSPECTION ABOUT MARCH 4, 198S t

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-(1300D)

Ebelosure 5 Page 5 of 8 PROCESSING BCAP IDENTIFIED DISCREPANCIES BCAP TASK FORCE SCOPE INSPECTORS DOCUMENTS DEVIATION "0BSERVATION" CSR ENGINEERING VALIDATES

" DISCREPANCY" REVIEW ALL DISCREPANCIES FOR PROGRAMMATIC IMPLICATIONS EVALUATE SARGENT AND LUNDY DISPOSITION OF DISCREPANCY SARGENT AND LUNDY SCOPE ASSOCIATED WITH BCAP DETERMINE DESIGN SIGNIFICANCE OF " DISCREPANCY" PROJECT CONSTRUCTION DEPARTMENT SCOPE PROCESS NON-CONFORMANCE REPORT FOR EACH

" DISCREPANCY" IMPLEMENT APPROVED CORRECTIVE ACTION PROJECT ENGINEERING DEPARTMENT /SARGENT AND LUNDY !. COPE EVALUATES, DISPOSITIONS AND DETERMINES SPECIFIC AND GENERIC CORRECTIVE ACTION Page 6 of 8 BCAP EVALUATES CSR_

DISPOSITION B

OF OBSERVATION b

AND DRAWS A BCAP WRITES CONCLUSION s

OBSERVATION A

n PROVIDES FURINER ON SPECIFIC s

2 P

INFORMATION TO BCAP r

POPULATION ITEM (MAY LEAD TO INVALIDATION)

PROVIDES P

AE DETERMINES PCD EVALUATES FURTHER VALIDITY OF OBSERVATION INFORMATION R

OBSERVATION TO BCAP (MAY LEAD TO INVALIDATION) 0 VALID OBSERVATION VALID OBSERVATION J

AE EVALUATES PCD WRITES E

& DETERMINES POPULATION NCR DESIGN OR SPECIFIC NCR b

SIGNIFICANCE OF EACH T

OBSERVATION w

Q.A. PROCESSES NCR 1.

Writes addendum to NCR as new observations are reserved.

v 2.

Suggests disposition of PED /AE EVALUATES specific observation.

AND DISPOSITION 3.

Review for 10CFR50 m

ALL OBSERVATIONS reporting.

AND DETERMINES GENERIC CORRECTIVE ACTION Evaluation & Disposition based on:

PCD DISPOSITIONS AND CDRRECTIVE 1.

Remaining design ACTION margins.

Generic corrective action based on:

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Trending QA REVIEW AND VERIFY CORRECTIVE ACTION e

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e CSR SAMPLE SELECTION TOTAL POPULATION HIGHLY.

STRESSED RANDOM

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1 JUDGEMENT 1

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BCAP STATUS

. MEETING for J anuary,

1985 INDEPENDENT EXPERT OVERVIEW GROUP we 29.

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February 14, 1985 1

1 Page 2 of 6

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o executi ve Summary Overview Activities o

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Page 3 of 6 OVERVIEW ACTIVITIES e

REINSPECTIONS o

Issued four IE0G observations, two on concrete and two on electrical.

Added i

an additional inspector to the IE0G staff.

AUDITS 1

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o Completed audit of BCAP QA inspector recertification files - no findings, no concerns.

l DOCUMENTATION REVIEW o

Issued three IE0G observations..

o Maintained reviews of BCAP obser-vations, S&L design significant evaluations and PCD NCR's.

o Maintained reviews of checklists, procedures and pl ans.

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CLOSED ISSUES 1)

Control points for reinspections.

2)

Resolution of documentation problems found during small bore piping con-i figuration review.

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OPEN ISSUES f

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Resolution of Inspector Reinspection el ement of RSCAP.

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Verification of the incorporation of activities to resolve IEOG observa-ti ons BCAP-0BS-006, -007, and -008.

i 3)

Resolution of IEOG observations BCAP-0BS-010 and -011.

l 4)

Incorporation of changes to CSR documents for incorporation of modi fications necessary to reflect selection of "high stress" samples.

4 1

$$ S"E !

EXECUTIVE

SUMMARY

o BCAP OVERVIEW Functioning as designed with checks and bal ances in pl ace.

o CSR ELEMENT Some rough edges during January.

Concrete pl acement inspections on hold.

o RPSR ELEMENT One checklist completed.

Compl eti on schedule recently extended to compensate for the volume of procedures requiring revi ew.

o RSCAP ELEMENT Program appears to be doing a thorough job of evaluating the elements within RSCAP.

o BCAP QA All inspectors now recertified and in the field performing inspections.

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--. _ ~.

~

Items Discussed at the NRC/ CECO /ERC Meeting February 14, 1985 4

Mr..Kaushal presented the status'of the three BCAP elements. A question was raised concerning the RPSR review of site procedures in effect on 6/30/84.

This question centered about the. time lag between 6/30/84 and the completion 1

of the procedure reviews. It was stated that if no concerns exist on the procedures as of 6/30/84, one can have confidence that no problem exists

'today. If concerns or problems are identified as of 6/30/84, these would have to be addressed on a case-by-case bases.

Mr. Kostel presented the status of processing BCAP discrepancies within 1-Sargent and Lundy.- During the presentation Mr. Keppler asked if, in the I

future, the discrepancies could be put in perspective with the number of items inspected rather than-the number of inspection packages completed.

i Mr. Wallace stated that these data are being developed.

i The 1900 and the NRC stated that they felt the Sargent and Lundy responses to some discrepancies need to be expanded to make the disposition clear.

Mr.

l Kostel stated that additional back-up information clarifying their disposition is filed in the Sargent and Lundy offices. He further stated that Sargent and Lundy will expand their future responses to make their disposition clear.

I Mr. Kostel completed his presentation by presenting examples of discrepancies received by Sargent and Lundy and their evaluation of these discrepancies.

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Mr. Smith presented the BCAP QA activities for the month of January. During his presentation, Mr. Forney asked if BCAP QA had problems closing CAR's (Corrective Action Requests) in a timely manner. Mr. Smith stated that BCAP QA was not experiencing a problem closing the CAR's.

Mr. Wallace and Mr. Kaushal presented the special topics. The topics j

presented were; the " Midpoint Look" at CSR activities, the processing of BCAP i

identified discrepancies and the engineering judgment sample selection. At j

the completion of these presentations the NRC stated that they will review the l

information and notify BCAP if they have an'y questions.

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Mr. Hansel presented the 1800 activities. This presentation included an executive summary, overview activities, closed issues and open' issues.

Mr.

Hansel stated that.the 1800 overview shows that BCAP is functioning as designed with checks and balances in place, t

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i Page 2 This concluded t.e presentation from CECO and IEOG to the NRC. At this time Mr. Warnick stated that he felt the presentation was a good one. He stated that discrepancies that are declared invalid by Sargent and Lundy need to have the basis for this clearly stated.

Mr. Warnick also stated that problems that arise at this stage of BCAP need prompt attention to resolve and close the issues. He stated he was pleased with the inspection feedback sessions which have been implemented by BCAP.

The next meeting was set for March 14, 1985 at 9:00 a.m. at the Mazon E.O.F.

Meeting was adjourned at 11:15 a.m.

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Enclosuro 8 Liot Cf Att nd:c3 BlE POSITION ORGANIZATION 1

R.IA. Gardner Reactor Inspector Region III, NRC R. F. Warnick Chief, Branch 1 Region III, NRC R. D.-Schulz Sr. Resident - Braidwood Region III, NRC f

L. G. McGregor SRI Braidwood Region III, NRC "W. L. Porney Chief, Projects Seciton 1'A Region III, NRC

.J. G. Keppler Regional Administrator Region III, NRC R. J. Lauer Attorney Isham, Lincoln & Beal i

E. D. Swartz Nuclear Licensing Admin.

CECO L. O. DelGeorge Asst. Vice-President CBCo i-C. W. Schroeder

-Proj. Lic. & Compliance Supt.

Ceco 1

M. Parker Chief, Div. of Engr.

Dept. of Nuc. Safety 4-D. H. Smith Nuclear Licensing Adm.

Ceco j

W. E. Vahle Proj. Field Eng. Mgr.

Ceco j

V. A. Hoffman Site Manager of SWEC SWBC

-M.

I. Miller Attorney Isham, Lincoln & Beal

-L. Kline Proj. Lic. & Compliance CECO D. L. Leone Projects Eng. Mgr. - BY & BR S&L G. F. Marcus Director of Quality Assurance CECO i

G. M. Orlov Asst. Director BCAP CECO R. L. Byers Asst. Director BCAP CECO K. T. Kostal Project Director Braidwood S&L j

R. E. Ham 1800, Asst. Project Manager ERC 1

J. L. Hansel 1800, Project Manager ERC N. P. Smith General Supervisor - QA Ceco D. L. Shamblin Proj. Const. Superintendent Ceco f

E. E. Fitzpatrick Asst. Manager QA Ceco T. J.' Maiman Manager of Projects Ceco N. N. Kaushal BCAP Director Ceco i

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'L.-S. Weiss, BCAP. - SWEC Deputy t'g.

SWEC D. L. Farrar Nuclear Licensing Ceco

.W. L. Chase Consultant ERC e

l M. Franco Consultant MRF&A 1

E..J. Siskin.

Vice-President GWEC M. J. Wallace Project Mgr.-

Ceco

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List of Attendees BtE POSITION ORGANI3ATICW R. C. Cannon BCAP-QA Ceco s

-P. Lickus Chief, State & Gov. Affairs WRC P. R. Pelke Project Inspector NRC A

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e BRAIDWOOD STATION BRAIDWOOD CONSTRUCTION ASSESSMENT PROGRAM i

REPORT PERIOD JANUARY 1 - JANUARY 31, 1985 I.

SIN 9mRY/ STATUS

- i This is~the seventh monthly progress report for the Braidwood Construction Assessment Program (BCAP), covering the period'from January 1 through January 31, 1985.

In the CSR area, the pace of inspections and related evaluations has increased. Advances were made in' visual inspections and document review package preparation and inspection.-' Visual reinspections for one population, Conduit,.were completed and related observations submitted to l

StL for evaluation. The RPSR effort was involved with unincorporated i

Field Change Requests (FCR's) and checklist development for personnel qualification / certification, construction and field coating work requirements. Progress continues on all active programs in the RSCAP element.

As of January 31, the number of personnel assigned to the BCAP effort has risen to 123. Satisfactory office and clerical support continues to be available to the BCAP work force.

II.

SCHEDULE ANALYSIS CSR activities are generally on schedule. RPSR'and RSCAP activities are, respectively,~six and one week behind schedule for achieving project interim milestones; however, the scheduled completion of the draft final BCAP report is not expected to be impacted.'

III. PERSONNEL AND WQUIPMENT STATUS BCAP manpower totaled 123 as of January 31.. Five additional inspectors were certified during January. Inspection personnel activities included training, accessibility walkdowns, reinspections, document reviews and supplemental observation detailing (e.g., weld mapping, configuration).

Conversion of observation and verification package tracking from Mapper to the IBM system was initiated. The~ program and data entry for verification packages has been completed.. Initial verification package

- I tracking reports are expected to be generated by the IBM system during the first week in February. The program and data entry for observation tracking is also expected to be completed during the first week in February.

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  • IV.

BCAP BLEMENT STATUS

'A.

CSR STATU_S Preparation of inspection packages and performance of inspections continued. Forty-nine of.70 checklists and instructions have been prepared. Of.these, 14 are being used for current inspections of plant. hardware-and documentation. Inspection packages are being 9enerated at a rate of about 250 per week..-Documentation reviews have begun in Concrete Placement, Conduit, and fanall Bore Pipe configuration.

Additionally, during this period, activities concentrated on 1) defining the three categories of the engineering judgment portion of the samples (related to safe shutdown, previously identified deficiencies, and high stress),

2) completing assembly of inspection packages for populations, 3) developing documentation 3

review checklists for the group of populations for which inspections have begun, '4) developing the remaining checklists and instructions and 5) processing observations.

On January 23, based partly on concerns expressed by the NRC--

resident inspector and partly on BCAP internal assessments, the inspections under the CSR element were temporarily suspended and a

" midpoint look" was initiated to factor-in the knowledge and ideas resulting from experience-to-date. As a result of this " midpoint look", specific actions were identified to enhance the quality of reinspection checklists and instructions and also the inspectors' understanding of these checklists and instructions. Action plans were also identified for reverification of previously completed inspections in the area of. Piping and electrical hangers / supports.

Inspections in the areas of concrete placement and electrical and piping hangers / supports were placed on hold pending completion of

.the identified actions.

Inspections in other areas were resumed on January 25, 1985.

B.

RPSR STATUS During January, the RPSR group was primarily involved in identifying unincorporated Field Change Requests (FCRs) that. affect specifications applicable to the RPSR effort and finalizing checklists that contain construction and personnel qualification / certification requirements. Three unincorporated FCRs-were identified. Requirements free-these PCRs have been added to checklists. A preliminary review of a sampling of sheets from the 29 checklists involved was conducted. 'Results of that review have been incorporated in 18 of the checklists. The remaining checklists will be updated in February.

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e Pinal review of the checklist for field coating work began on Jar.uary 24.

Comparison of contractor procedural requirements to that checklist is scheduled to stari. on February 4.

The next checklist to be reviewed will be for inspection and testing services.. Comparison of contractor procedures to this checklist is scheduled to be completed in late February.

C.

RSCAp STATUS In January, the RSCAP Group completed preparation of Colonitment

. Lists, Procedure Review Check Lists, Implementation Review Checklists and Documentation Review Checklists for each of the l

Corrective Action Programs under RSCAP Review. Field Review of Contractor Implementation and Documentation Reviews were also conducted this month. Several observations have been initiated as a-result. BCAP-QA conducted'several surveillances of the RSCAP.

element with no findings.

i V.

PROBLiptS/DISCREPENCY FINDINGS A.

Implementation Problems No specific implementation problems were experienced during this l

period.

i B.

Discrepancy Findings

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A total of 1486 observation reports have been wr'itten as'of January 31, 1985. of these,'the review for validity has been completed for 1017. Of these, 865 have been determined to be valid discrepancies.: Those forwarded to S&L for design significance determination currently number 617.-

As of the end of this report period, S&L has not' identified any

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' discrepancy as design significant.

VI.

RECOf91BNDATIONS i

No specific recommendations are offered at this. time.

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.b N. M. Kaushal

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BCAP Director 4

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