ML20127D629
| ML20127D629 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 08/10/1984 |
| From: | Hansel J EVALUATION RESEARCH CORP. |
| To: | |
| Shared Package | |
| ML20127D578 | List: |
| References | |
| NUDOCS 8506240288 | |
| Download: ML20127D629 (52) | |
Text
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Doc. No. LCAP 001 Rev. 1 EVALUATION RESEARCH CORPORATION QUALITY ASSURANCE PLAN BRAIOWOOD CONSTRUCTION ASSESSHENT PROGRAM (BCAP) p
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SUMMARY
OF REVISIONS DATE REV. REVISION 8/10/84 1 Section 1, paragraph 1.1, page 4. Identified the Team Leade'r for QA and Audits as the individual ~ responsible for inspection and auditing of BCAP activities.
8/10/84 1 Sectio. 1, Figure 1.1-1, page 5. ERC/8 CAP Organiza-tional Chart redrawn to more clearly show the reporting level of the QA Manager. Also removed proper names from chart.
8/10/84 1 Section 1, Figure 1.1-2, page 6. ERC/BCAP Organiza-tional Structure - removed proper names from chart.
8/10/84 1 Section 1, paragraph 1.3, page 7. Identified training
- of BCAP Project personnel as the QA Manager's responsi-blitty.
8/10/84 1 Section 18, page 21. Included mention that objective evidence is examined for compliance with QA Program '
requirements and documented during audits.
8/10/84 1 Section 18, page 22. Included the responsibility of the QA Manager to perform periodic internal audits of the BCAP Task Team.
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P BCAP 001 Rev 1 TABLE OF CONTENTS ,
Page 0.0 Introduction *
...................... I 1.0 Organization and Responsibilities . . . . . . . . . . . . 3 1.1 Project Organization . . . . . . . . . . . . . . . . 3 1 1.2 Responsibility of Project Manager. . . . . . . . . . 4 1.3 Quality Assurance Manager. . . . . . . . . . . . . . 7" 1 1.4 Qualification Requirements . . . . . . . . . . . . . 7 2.0 Quality Assurance Program . . . . . . . . . . . . . . . . 8 2.1 Quality Assurance Plan . . . . . . . . . . . . . . . 8 2.2 Personnel Qualifications . . . . . . . . . . . . . . 11 2.3 Training . . . . . . . . . . . . . . . . . . . . . . 11 3.0 Design Control . . . . . . . . . . . . . . . . . . . .. 12 4.0 Procurement Document Control .............. 12 5.0 Instructions, Procedures, and Drawings ......... 12 6.0 Document Control . . . . . . . . . . . . . ....... 13 7.0 Control of Purchased Material, Equipment, and Services. . 14 8.0 (dentification and Control of Haterials Parts, and Components . . . . . . ................. 15 9.0 Control of Special Processes .............. 15 10.0 Inspection ....................... 15 11.0 Test Control ...................... 16 12.0 Control of Heasuring and Test Equipment . ........ 16 13.0 Handling, Storage, and Shipping . . . . . . . . . . . . . 16 4.0 Inspection. Test, and Operating Status ......... 16 15.0 Nonconformin,g Materials Parts, or Components . . . . . . 17 90
TABLE OF CONTENTS (continued)
Page 16.0 Corrective Action . . . . . . . . . . . . . . . . . . . . 17 17.0 Quality Assurance Records . . . . . . . . . . . . . . . . 18 18.0 Audits . . . . . . . . . . . . . . . . . ........ 19 1 App (n % ! ........................... 23 e
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LIST OF ILLUSTRATIONS Page 1.1-1 ERC/8 CAP Organizational Chart . . . . . . . . . . . . . . 5 1 1.1-2, ERC/8 CAP Organizational Structure . . . . . . . . . . . . 6 P
LIST OF TABLES 2.1-1 BCAP Quality Assurance Program Index .......... 9 e
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0.0 INTRODUCTION
This Quality Assurance Plan describes the Quality Assurance Program which the ERC Independen,t Expert Overview Group will apply tq the scope of work for the Commonwealth Edison Company, Braidwood Construction Assessment Program (BCAP) at the Braidwood Station, Braceville, Illinois.
The plan is designed to assure that the program activities affecting the validity of the progran results will be conducted in accordance with the applicable quality assurance requirements of 10 CFR Part 50, Appendix B as identified later in this plan.
The Independent Expert Overview Group activities will include the following:
o Conducting an overall review of the BCAP scope docunent objectives and a review of each of the BCAP elements. Determining if the BCAP elements will fulfill the objectives.
o Ascertaining if the BCAP effort, as identified in the scope docu-ments, is properly focused and whether the goals of the BCAP are being fulfilled.
o Conducting a minimum of two (2) audits that will address the im-plementation of each of the BCAP elements. Items to be specifi-cally audited will be adherence to Program procedures, evaluation of Quality Assurance involvement, qualifications of the personnel 93
performing inspections, and identification of nonconformances and adequacy of the corrective actions.
o Performing an independent review of selected BCAP identified dis-crepancies to provide assurance that the engineering evaluation for design significance was adequately performed and docunented.
o Preparing in-depth audit reports.
o Preparing periodic status reports and a final report summarizing their overview activities and summary conclusions.
To conduct an independent overview of this type, it is essential that the Overview Group operate with some degree of freedom. The Overview Group will find it necessary to monitor Ceco and it's subcontractors in a nunber of ways to determine if the BCAP objectives are being fulfilled, i.e.,
attend meetings, review plans and procedures, conduct random and unstruc-tured surveillances and reviews of certain aspects of the program, assess the process for identifying discrepancies and the methods used for determ-ining corrective action. These activities will be aimed at the Overview Group gaining insight into the effectiveness of BCAP and are not intended to influence or control the level of quality achieved in the facility. It is for this reason that they will not be addressed in this plan.
The Overvfew Group will be required to perfonn certain tasks that come under the purview of 10 CFR Part 50, Appendix B, i.e., audits, inspections, 94
training, records management, etc. This Quality Assurance Plan identifies the applicable criteria and the controls that will be applied by ERC.
1.0 ORGANIZATION AND RESPONSIBILITIES 1.1 PROJECT ORGANIZATION Evaluation Research Corporation (ERC) as an outside organization will bring together and direct a team of experts whose purpose will be to pro-vide an independent overview of the BCAP. ERC has formed this team of senior experts and professional staff to work under the direction of a Principal Consultant, who will be ,hereafter referred to as the Project Manager.
The Independent Expert Overview Group members will be free of any significant contacts with Connonwealth Edison Company. They will not have participated in the design, construction or quality assurance activities related to the Braidwood Station or with Braidwood site contractors within the past five years. Immediate family members will not be currently em-played by Connonwealth Edison Company or a Braidwood site contractor. Mem-bers of their immediate family (parents, spouse, children and grand-children) will not currently have a cumulative ownership and creditor interest in Connonwealth Edison Company or a Braidwood site contractor which exceeds 5% of the f amily annual income.
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The Overview Group will conduct a con .sive third-party overview of the 8 CAP, thereby providing an added measure of assurance in the con-fidence of the results of the BCAP.
ERC personnel conducting the BCAP overview will be organized (Figure 1.1-1) into task teams, consisting of senior expert team leaders and pro-fessional staff reporting to the Project Manager. The Team Leader identi-fled for the Quality Assurance and Audits will be responsible for assuring that tests, inspections, exaninations, and audits conducted in conjunction 1 with BCAP are in accordance with the requirements of this Plan and imple-menting proceduers by personnel qualified or certified as required. The overall team will operate independently of the various Braidwood organiza-tions and will communicate with Connonwealth Edison through a designated Commonwealth Edison representative. The task teams will have access to the Braidwood Station and access to contractor personnel, facilities and rec-ords associated with the Braidwood Station.
As shown in Figure 1.1-2, the overview team is matrix organized into task teams each having vertical responsibilities by discipline and horizon-tal by methodology. This provides a more cohesive means of performing the overall assigned task. ,
1.2 RESPONSIBILITY OF PROJECT MANAGER The ERC Project Manager, who is reponsible for the overall activities of the Independent Expert Overview Group, reports directly to the Common-wealth Edison (CECO) Manager of Projects, who reports to the President and 96
EVALUATION RESEAECH CORPOEATION CECO Manager of Projects ERC Project Manager Ass't. Project Manager Assu cc Administration I
nd Pip.
Electrical HVAC g, ,,, OA & Audits Figure 1.1-1. ERC/8 CAP Organizational Chart
EVALUATION RESEARCH COEPOEATION .
CECO Manager of Projects ERC Project Manager Ass't. Project Manager
) Quality Assurance Administration -
nd P6* g Electrical HVAC OA 6 Audits Stru t ral 1
CSR f
S C
i i P
RCSAP METHODOLOGY m
^
N E
V BPSR s
Records Mgm*t.
Figure 1.1-2. ERC/BCAP Organizational Structure
' Chairman of the Board of Ceco. The ERC Project Manager will regularly report to the Manager of Projects regarding the effectiveness of the BCAP program.
1.3 OUALITY ASSURANCE MANAGER The Quality Assurance Manager reports to the ERC Project Manager.
This level of reporting provides organizational freedom to identify quality problems and verify implementation of solutions. It also assures appropri-ate attention.and high priority at the top management level. He has no
. 1 other duties or responsibilities unrelated to the overview program that would divert his full attention from the overview function. This organi-zational structure avoids any compromise of program quality due to other requirements such as scheduling and costs.
The Quality Assurance Manager is responsible for assuring that the Overview Group complies with the requirements of this Quality Assurance Plan. The QA Manager shall also assure that ERC personnel assigned to /1 BCAP are indoctrinated, trained, and certified, as required, in accordance N
with applicable procedures.
1.4 OVALIFICATION REQUIREMENTS The Quality Assurance Manager shall have the following minimum quali-fications:
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- 1. Shall have either a B.A. or B.S. degree or equivalent.
- 2. Shall have a miniatm of 10 years experience, with at least 5 years i
of supervisory experience, in quality assurance, engine ~ering, manufacturing and procurement, or combination thereof, associated 9 with nuclear facilities or equivalent operations. A minimum of 3 years of this experience shall be in Quality Assurance.
- 3. Shall possess a knowledge and understanding of applicable stan-dards, regulations, and codes such as the ASME Boiler and Pressure Yessel Code. He shall have a working knowledge and understanding I
of quality assurance methods and their application.
- 4. Shall be experienced in organizing, directing, and administering an overall progran or activity, or a major portion of an overall program having broad scope and application.
2.0 QUALITY ASSURANCE PROGRAM 2.1 QUALITY ASSURANCE PLAN This Quality Assurance Plan recognizes the need to establish and im-piement a Quality Assurance Progran in accordance with the quality assur-ance requirements of 10 CFR Part 50, Appendix B. The Quality Assurance Program is documented by written policies and procedures. These documents define the details of how work is performed and verified to meet the quality requirements of the program. The procedures which apply to the 100
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j BCAP program are identified in Table 2.1-1 of this plan. These specific procedures are maintained in controlled manuals. The Project Manager has approved the QA Plan and issued a directive to all personnel who either perform or verify work t, hat compliance with the Quality Assurance Plan is mandatory. The Plan is maintained and controlled by the Quality Assurance Manager and is reviewed at least annually and modifed as necessary to keep i t current and up-to-date.
2.2 PERSONNEL QUALIFICATIONS ERC determines the initial capabilities of employees and contract per-sonnel (hereaf ter referred to as empicyees) by verifying the professional (both educational and employment) qualifications.of all new hires in ac-cordance with standard employment practices. Records of these verifica-tions are maintained in the employee's personnel folder. The employee's continued proficiency and understanding of job requirements are monitored on an on-going basis and documented annually through management assess-ments, which includes proficiency testing where appropriate.
During the BCAP program, ERC will determine compliance to requirements through selected hands-on reinspections, and reviews of inspection docu-mentation and inspector qualification records. All ERC reinspection veri-fication operations will be performed by personnel qualified or certified as required by procedures, codes, specifications and standards.
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TABLE 2.1-1 BCAP QUALITY ASSURANCE PROGRAM INDEX Quality Elements Impicmenting Procedures and Titles
- 1. ORGANIZATION QAP-1.1 Personnel Qualifications (10CFR50, Criterion II) QAP-1.2 Indoctrination and Training of Personnel
- 2. QUALITY ASSURANCE PROGRAM DP&P-101 Quality Assurance Policy (10CFR50, Criterion III)-
- 3. DESIGN CONTROL N/A (10CFR50, Criterion IIII)
- 4. PROCUREMENT DOCUMENT CONTROL QAP-4.1 Procurement Docunent Control (10CFR50, Criterion f!V) ,
- 5. INSTRUCTIONS, PROCEDURES & QAP-5.1 Preparation, Review and DRAWINGS Approval of Quality Assurance .
(10CFR50, Criterion fV) Procedures
- 6. DOCUMENT CONTROL .
QAP-6.1 Distribution and Control (10CFR50, Criterion IVI) of Quality Assurance Docu-ments
- 7. CONTROL OF PURCHASED MATERIAL, N/A EQUIPMENT, AND SERVICES (10CFR50, Criterion IVII)
- 8. IDENTIFICATION AND CONTROL OF N/A HATERIAL, PARTS, AND COMPONENTS.
- 9. CONTROL OF SPECIAL PROCESSES N/A (10CFR50, Criterion flX) -
- 10. INSPECTION QAP-10.1 Quality Review and Sur-(10CFR50, Criterion IX) veill ance QAP-10.2 Qualification of Inspection Personnel
- 11. TEST CONTit0L N/A (10CFR50, Criterion flX) 102
TABLE 2.1-1 (continued)
GCAP QUALITY ASSURANCE PROGRAM INDEX Quality Elements Implementing Procedures and Titles
- 12. CONTROL OF MEASURING AND N/A TEST EQUIPMENT (10CFR50, Criterion #XII)
- 13. HANDLING, STORAGE, AND N/A SHIPPING '
(10CFR50, Criterion fXIII)
- 14. INSPECTION, TEST, AND N/A OPERATING STATUS (10CFR50, Criterion #XIV)
- 15. NONCONFORMING MATERIAL, QAP-15.1 Documentation and Dispost-
- PARTS, OR COMPONENTS tion of Observations and -
(10CFR50, Criterion fXY) Discrepancies
- 16. CORRECTIVE ACTION QAP-16.1 Corrective Action (10CFR50, Criterion fXVI)
- 17. QUALITY ASSURANCE RECORDS QAP-17.1 Quality Assurance Records (10CFR50, Criterion fXVII) Program
- 18. AUDITS QAP-18.1 Quaitty Assurance Audit (10CFR50,, Criterion #XVIII) Program i QAP-18.2 Qualification of Audit Personnel 9
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l 2.3 TRAINING l
Indoctrination and training sessions are conducted for all new project members. This training is accomplished in group sessions and individual discussions covering the purpose, scope, and implementation of quality-rel ated manuals, procedures and instructions.
3.0 DESIGN CONTROL Evaluation Research Corporation has no responsibility for design control within the Braidwood Construction Assessment Program.
4.0 PROCUREMENT DOCUMENT CONTROL Evaluation Research Corporation responsibility for the BCAP does not include the requirement to purchase material or equipment, however, inde-pendent contractors' services are contracted. Contract actions are initiated by the cognizant ERC person. It is the responsibility of the requisitioner to identi fy the requirements and qualifications required of the contractor. The procurement document shall specify the qualification or certification documentation required, and need for security clearance.
These procurement documents are reviewed and approved by the Quality Assurance Manager.
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l 5.0. INSTRU,CTIONS. PROCEOURES. AND DRAWINGS The Quality Assurance Program provides that all activities affecting quality are to be accomplished in accordance with documented policies and procedures and that appropriate quantitative and qualitative means, of veri-fying quality are to be satisfactorily delineated and included as appro-pri ate. As such, ERC uses written procedures implementing the Quality.
Assurance Program requirements to provide assurance that all activities affecting quality are planned, controlled, and documented as appropriate.
Each procedure contains detailed instructions for the erecution of ac-tivities in accordance with the approved Quality Assurance Program. Ap ,
proval and distribution of procedures and changes to those procedures are controlled by the Quality Assurance Manager. Detatis of measures imple-mented to control preparation, review, approval, release, change, and dis-tribution of procedures and instructions a're described in Section 6.0 of this document. When issued, proced,ures are mandatory for all personnel either performing or verifying quality-related activities for BCAP by ,
written directive from the ERC Quality Assuranc'e Manager.
4 6.0 DOCUMENT CONTROL Policy and procedure docoments for the BCAP are subject to control.
The measures implemented for document control are contained in the various procedures of the Quality Assurance Manual. Controls are imposed for initial review and approval actions, release of the documents and for dis-tribution of the documents to designated personnel who either perform or l
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3 verify quality related work to assure that they are available at the to-cation where the prescribed activity is performed. Revisions to these documents are reviewed and approved by the same organizations who approved the original documents. ,These revisions are distributed in the'same manner as the initial issue.
I The Quality Assurance Plan for BCAP is, prepared, maintained, dis-tributed and controlled by the Quality Assurance Project Manager. , i Policy and procedures documents are either distributed to authorized 4
manual holders or to standard distribution lists with receipt acknowledge-ment required. Distribution is controlled to assure availability of the documents, and revisions, to all affected personnel. An updated controlled table of contents is issued to affected personnel when a revision to a pro-cedure is issued. This mechanism provides immediate visibility to the user to assure that an obsolete issue is not followed in either performing or verifying work. Holders of the various manuals are responsible to update their manuals as revised procedures are received, by inserting the revised procedure and destroying the superseded procedure.
7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES As stated in Section 4.0, " PROCUREMENT DOCUMENT CONTROL", Evaluation Research Corporation's responsibility for the BCAP does not include the
,1 requirement to purchase material or equipment, however, independent con-tractors' services are . contracted. The Quality Assurance Program describes 106 .
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controls for assuring that purchased services conform to procurement docu-ment requirements and that independent contractors meet the professional qualifications for the task to be assigned. These control measures include, as appropriate,* evaluation and selection of contract personnel, evaluation of contractor performance effectiveness, and examination and appraisal of doctnents generated during course of effort (reports, specifications, drawings, etc.). Assessmerits of performance shall be perfomed at intervals consistent with the importance, complexity, and duration of the service. Records of these qualifications and assessments are maintained in the Quality Assurance Manager's files.
The provisions of this section do not apply for services where special skills do not apply.
8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS Evaluation Research Corporation has no responsibility ,for identifi-cation and control of materials, parts, and cotoponent:; within the Braidwood Construction Assessment Program.
9.0 CONTROL OF SPECIAL PROCESSES '
The control of special processes such as welding, heat treating, non-
' destructive examination, cleaning, bonding, coating, soldering, plating and hard surfacing, is a function for sich ERC has no direct responsibility -
within the BCAP program.
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10.0 INSPECTION ERC has no direct responsibility for inspection activities affecting quality within the Braidwood Construction Assessment Program. Aowever, during the BCAP program, ERC will determine compliance to requirements through selected hands-on reinspections, and reviews of inspection docu-mentation and inspector qualification recor'ds. All ERC reinspection veri-fication operations will be performed by personnel qualified or certified as required by procedures, codes, specifications and standards.
All reinspection and document review activities and the results will be docunented in accordance with applicable procedures and submitted to the Quality Assurance Manager for review and reporting to BCAP.
11.0 TEST CONTROL l
ERC has no direct responsibility for test control ac,tivities within the Braidwood Construction Assessment Program.
I 12.0 CONTROL OF MEASURING I.ND TEST EQUIPMENT ERC has no direct responsibility for the control of measuring and test equipment vd thin the Braidwood Construction Assessment Progran.
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13.0 HANDLING, STORAGE, AND SHIPPING ERC has no direct responsibility for handling,. storage, and shipping activities within the Brai'dwood Construction Assessment Program.
14.0 INSPECTION, TEST, AND OPERATING STATUS ERC has no direct responsibility for inspection, test, and operating status activities within the Braidwood Construction Assessment Program.
15.0 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS ERC has no direct responsibility for activitie's related to noncon-formance, parts, or components within the Braidwood Construction Assessment Program. However, nonconforming items identified by ERC during reinspec-tion and document review activities will be documented and brought to the immediate attention of BCAP management for resolution within the BCAP Quality Assurance Program. ,
The Project Quality Assurance Manager shall assure that all noncon-formances identified by ERC are documented in accordance with BCAP pro-cedures.
16.0 CORRECTIVE ACTION ERC has no direct responsibility for corrective action activities within the Braidwood Construction Assessment Program. However, conditions 109
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adverse to quality or deficiencies in the BCAP and implementing procedures which indicate that program objectives may not be fulfilled which are identified by ERC shall be docunented.
The Project Quality Assurance Manager shall report these situations to the appropriate BCAP management and shall assure that appropriate correc-tive actions are completed. .,
17.0 QUALITY ASSURANCE RECORDS Commonwealth Edison Company has the responsibility for the BCAP Quality Records Management System. The specific inspections and reviews performed under BCAP together with the results of these inspections and reviews with objective evidence for traceability and reproducibility will be documented by the BCAP organization in a manner suitable for auditing.
Such documentation will be retained as permanent quality re, cords as stated in the BCAP program docLment.
Those records which are necessary to document the quality assurance activities perfoimed by ERC personnel are listed in ERC procedures along with the organizational responsibil'ity for their collection, maintenance, storage, and retrieval .
These records shall include, but are not limited to:
l o Quality Program Plans and Manuals l o
- Procedures l 110
o Procurement Docoments to Contractors o Personnel Qualifications o Activity Reports o Audit Packages (Plans, Reports, etc.)
o Verification and Evaluation Documents Duplicates of ERC records identified by the BCAP Project Manager as quality records will be transferred to the BCAP Records Management Opera-tion for incorporation into the BCAP records system. Record storage fa-cilities at ERC are located in an area which has fire, water, and environ-mental controls that comply with the requirements and regulations covering office space provided for employees. Duplicate copies as required may be -
available at the ERC work areas at the Braidwood Station.
18.0 AUDITS An audit program will be maintained and implemented a minimom of two (2) times which will address the implementation of each BCAP element.
Items to be specifically audited will be adherence to program procedures, I
evaluation of Quality Assurance involvement, qualifications of the person-nel performing inspections, and identification of nonconformances and adequacy of the corrective actions. '
t Procedures are established and implemented for conducting these au-
- dits. Audit pl ans are developed, implemented, and documented in accordance l
with these procedures. The audit teams will consist of a lead auditor quali fied in accordance with ANSI 45.2.23. "Quali fication of QA Program
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Audit Personnel" and team members with appropriate training and experience to evaluate the adequacy and implementation of the BCAP elements. In order to preserve objectivity in the audits, the teams will be composed of mem-bers of the ERC task force who have no direct responsibility for the area or activity being audited.
The salient elements of the audit program are:
o Audits are scheduled and initiated sufficiently in advance to assure effective Quality Assurance Program implementation during the BCAP program.
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o Planning of audits results in a docunented audit plan which identifies the specific activities to be audited, the require-ments upon which the audit is based, the team members, and tean leader.
o Notification of the responsible management of the work ac-tivity to be audited identifying the audit plan, tean members, and audit date.
o Preparation of the docunented audit checklists by the audit teau and the orientation of tean members by the audit team
. leader prior to the audit.
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o Conduct of audits in accordance with the prepared checklists, to include the documentation that objective evidence was / 1 examined for compliance with QA Program requirements.
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o A post-audit conference to discuss audit findings at the con-clusion of the audit, with the management personnel responsi-ble for the audited activity.
a o Documentation of audit results, including critique, to the management responsible for the work audited.
o Response from the management responsible for the work audited indicating corrective action taken, or to be taken, to pre-clude recurrence of deficiencies and a " scheduled completion date.
o Evaluation of adequacy of the response and follow-up to assess implementation of corrective action.
o Reaudit of deficient areas, if necessary, and documented closeout of open items.
The documentation aforementioned shall consist of a written report distributed to the BCAP Project Man ~ager and will contain the following information as a minimum:
o Description of the audit team, the audit performed and the .
criteria used, o The audit findings including copies of Audit Action Reports.
o The audit conclusions. .
o Any agreement made with the audited organization to implement corrective actions including a time schedule for such imple-mentation.
The reports require that the audited organizations reply within an agreed to time following receipt of the audit report, identifying planned corrective actions for deficiencies and a schedule for implementing the corrective actions.
Quality Assurance follow-up of the corrective actions is accomplished to confirm that the actions have been completed as scheduled. Closeouts of all significant findings are documented.
i The ERC Quality Assurance Manager will audit the Task Team to verify
, compliance with the requirements of this Plan and the applicable imple- /
ss 1 menting procedures. Audits will be conducted annually or at least once l during the life of the Project, whichever is shorter.
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APPENDIX !
The following ANSI Standards are used as guidelines for dev' eloping applicable ERC procedures for the BCAP program.
- 1. N45.2 Quality Assurance Program Requirements for Nuclear Power Pl ants
- 2. N45.2.6 Qualifications of Inspection,. Exanination and Testing Personnel for Nuclear Power Plants
- 3. N45.2.9 Requirements for Collection, Storage and Maintenance of Quality Assurance Records for Nuclear Power Plants
- 4. N45.2.10 Quality Assurance Terms and Definitions
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- 5. N45.2.12 Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants
- 6. N45.2.23 Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants l
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. APPENDIX E. Observations l
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.. QAP-15.1 EVALU ATIO N Attachment 6.1 RESEARCH CO R P ORATI O N OBSERVATION REPORT Observation No. 8CAf) Of J 00]
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Response (Requested within 30 days of above date.):
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c W u ','p c u . ) ..? l u o ol & 05 cats'4 p e y t h u n .. > z c c y &
& emAzaenzs. .
e b
119
Page 1 - Attachment
- to BCAP-OBS-001 dated August 28, 1984 Responses to specific observation statements in BCAP-OBS-001 in order of appearance within the description are:
- 1. Observation. " Daniel is not an approved contractor, therefore ..." .
Response - Daniel is an approved contractor - see Exhibit A attached.
- 2. observation. "In fact, the entire Certification program is being administered by Daniel personnel, none of which have been certified in accordance with BCAP-08
- e Response - Activities performed to date have either not been required to be performed by certified personnel or the items have been pre-approved by CECO Certified Level III personnel.
In addition the Daniel personnel are appropriately qualified to administer an inspector indoctrination and training program. The appropriate Daniel personnel will be certified in accordance with BCAP-08 provisions prior to performing personnel certifications or any BCAP CSR
- element reinspections or document review activities. The BCAP-08 Certification program has been evaluated and found acceptable by CECO QA
- Level III personnel and other Ceco representatives (See BCAP-08 approvals and Exhibit B attached).
- 3. observation. " Records of OJT. class attendance, reading assignments, etc. are being signed as acceptable by individuals who are not yet certified."
Response - None of the above documents have been used as records for BCAP certification. The individuals performing the subject acts are qualified I to perform the referenced activities. The alleged improper activities do i not require certified personnel. The use of these documents as a basis for certification will require an appropriately certified person.
j
- 4. observation. "oJT records have been signed " Level III Inspection Lesd" by non-certified personnel."
Response - These documents have not been used as a baer for the additional BCAP Cetification. The Level III Inspectic.. i.ead is an
, approved BCAP title and the individuals signing these onos are l appropriately qualified Level III Lead Inspectors; however, they are not l
yet BCAP certified. These documents will be reviewed . .! signed by the BCAP certifying authority if used as a basis for BCAP k*ogram certification.
120 (0300J)
. Page 2 - Attachment to BCAP-OBS-001 dated
. August 28. 1984
- 5. observation. "It is not clear either as to who will certify the
" Certifying Authority," the BCAP Inspection Supervisor."
Response - Paragraph 3.4 of BCAP-08 clearly designates the BCAP Inspector Supervisor as the BCAP Certifying Authority. This procedure document is approved by the Braidwood Project Manger, BCAP Director, and a CECO QA Level III.
- 6. Observation. "ASME/ ANSI N45.2.6 requires that the identification of the Certifying Organization appear on the Certification documentation."
Response - The principal BCAP document which fulfills the ANSI N45.2.6 written certification requirements is titled "BCAP Document of Certification" (Exhibit C). Space 5 on this form will bear the name and i signature of the BCAP Certifying authority who is a Daniel employee.
Daniel International Corporation will be identified in Space 5. This is adequate to fulfill the referenced requirement.
i l
l l
l l
(0300J) 121
EXHIBIT N' August 16, 1984 6-12-84-37
Subject:
Approved Bidders List Daniel International Corp.
- Technical Daniel Services Division Centre Greenville S.C. 29602 Mr. R. E. VanDerway: A
~
The Station Nuclear ',ngineering Department and the Quality Assurance it complies with all appplicable criteria of Titl Program of the Subject the that Vend Federal Regulations, Partj50, Appendix B. e 10 Code of technical objections, we recert. mend thatOn the basis of this e added to the Approved Bidders List the Subject vendor be Safety-Related inspection services. as a supplier of Stati i
/ t-!7- 3 d uclear Engineering Manager
/
/ '
Ma (a) aof Qua f~ZSi - Pt.
ty Assurance i JFD:kaa .
5501Q - '
Attachment -
' cc: W. J. Shewski I
i
\
_, _ _ _ . _ - - - - - - - - - ~ _
___.e-e.-- * ' ' ' ' ^
- EXIIIBIT B TO: D.11, itcAfee
- FROM: H. J. Lapp. Jr.
DATE: August 28. 1984
SUBJECT:
Review of BCAP Procedure BCAP-08, Qualification and Certification
, of Reinspection Personnel.
I have completed the review of the Braidwood Construction Assessment Program's Procedure. BCAP-08, Qualification and Certification of Reinspection Personnel,.
Based on that review I have found BCAP-08 to be in compliance with Project Management's training procedure PM-06, Project Training Requirements and Records.
It is also in compliance with PM-03, Braidwood Project New Dnployee Orientation Training Program.
lp '
3l H. J. Lapp, Jr.
Project Training Coordinator cc: Pile X.2 R. C. Schleiter HJL/kaw (0166k) l -
{
123
r EXHIBIT C BCAP DCCt't.1E.NT OF CE.:iTIFICAT:C.N 1.swtOVEENaut
$CC;4L J4;. Rarv Nt.us&A t .
- 2. #n t 5:CA L i A AMINA I4ON
' 3. EV E sA A1.slNATION -
I
- 4. CERTIFICATlON Os5Ci?Uhl I
SG SCISC;FLINE LIV E*.
- 5. CE A TIFIED .
CA?i 6.,OA Ti OF CiaTaf tCATION EXPIRA74CN
. $UAtMARY OF; A. EDUCATION
- t. i A9theihCi .
.. . Wk.
. l o W-dit.: < C c.iCas ra4 .CN ,ig2.L :; ~~
me e-124 r.-
- y.
EVALU ATIO N
- RESEARCH CO RPO RATIO N OBSERVATIO!! REPORT Observation No. 36Ap.o8s-ooPL, Oate Sep-/-n Aer-m M24 To: M. Musho.\ From: ERC Project Manager 8 CAP Director TAF<A% Le '
9/is/sq .
4 L ufSlS"&"T*
Obseryatton:4A ge:t:ir i 2.64
/8 P (G.S2 49&z.W M sdn M 8eff- -a.,-a h'E=&
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.ma -a.4
- 4 ,
pm' *
,2, M ObA '
E &p,es e '
x - ~9 ~ SM,YAL ,
Si na re of Origna r Date s
- " S Response (Requested within 30 days of above date.):
BCAP Director Date Response is Accep table Unacceptable RCA flo. Issued Signature Date ERC Project Manager ,
s QF-15.1.1 8/84
- page t or qgg ~. -*
e 0 e
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- b. M M o d am A. W q M J aneu b a w
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- 6. ~ / si se k 6
L
APPENDIX F. Audit Reports 127
W .
e FIELD OPERATIONS EVALUATION
-EESEAECH 17ss sorterson oavis His suitesoo CO7PQEATION Artinotoa. Virolaia 222o2 (703)979 8220 September 11, 1984 BCAP 018 .
.soo oak Rwse Turnoike suae soi
. oak Ridge. Tennessee 3783-Commonwealth Edison Company '*" "*****
Braidwood Station R.R. #1, Box 81 Braceville, Illinois 60407 -
Attention: Mr. N. Kaushal
SUBJECT:
Independent Expert Overview Group Audit (ERC 84-101) conducted September 11-12, 1984
REFERENCE:
A. E. Cocoros to N. Kaushal letter serial BCAP-010 dated September 5, 1984
Dear Mr. Kaushal:
This letter is to transmit the report of the subject audit announced by the reference letter. There were no findings of deviation noted, however, a comment was passed on to Mr. M. Dougherty that consideration should be given to providing a statement to the documentation of the sample size selection (par. 4.4) for a sample size expansion in the event of abnormal findings. Since there were no findings, no response is required.
The audit team wishes to express its appreciation t'o the BCAP personnel for their courtesies and cooperation during the course of the audit.
Any questions on this subject are to be addressed to the writer, Ext. 2787.
Yours truly, A. E. Cocoros, Manager Quality Assurance AEC/sjs cc: T. Maiman R. M. Pokorn R. N. Gardner J. G. Keppler BCAP Team File (2) 128
. . l e . e' \
I i
- \
.l l Attachment to BCAP-018 Page 1 of 3 Report Audit ERC 84-101 ERC Audit of BCAP '
Date: Sept. 11-12, 1984
Purpose:
The purpose of the audit was to assess compliance with t'he requirements of BCAP-60 "RSCAP-Review Method".
Audit Team:
A. E. Thompson C. M. Cocoros - -ERC ERCLead Auditor J. E. Young - ERC The at audit 8:30 a.m.was initiated with an opening meeting on September 11 , 1984, The audit's purpose, scope and agenda wel:e presented.
The results on September 12, of the1984, auditatwere 9:00presented p.m. at the close our meeting held are provided in Attachment A. The attendees of'those meetings Audit General:
The audit was the following conductedofusing paragraphs checklists containing the requirements of BCAP-60; 4.1.7.4, 4.1.2, 4.1.3, 4.1.4, 4.1.5, 4'l.6, 4.1.8.1, 4.1.8.2, 4.1.8.3, 4.2.2, .
4.3.2, 4.3.3, 4.3.4, 4.2.3, 4.2.5, 4.2.9, 4.2.10, 4.3.7, 4.3.8, 4.4.1, 4.5, 4.5.3, 4.5.4, and 4.5.5.
At the time to the pointofofthe auditauditable.
being only two of the nine programs had progressed contacted were: The two programs audited and personnel 1.
Program 004 " Quality Control Structural Steel Review"
! (QCSSR)
- a. M. Dougherty
- b. L. Rouen r
2.
Program 006 " Safety Related Pipe Supports"
- a. M. Dougherty
- b. E. Kurtz
- c. T. Parker i
1 129
s . e, Attachment to BCAP-018
. Page 2 of 3 Audit Findings:
During the review of each paragraph outlined above for the two programs, there were no findings of deviation identified. -
General comments: ,
consideration should be given to providing a statement to the.documenta-tion in theofevent the sample size selection of abnormal findings.(par. 4.4) for a sample size expansion 130
. . s'.
}
1 Attachment to BCAP-018 I
Page 3 of 3 Attachment A ERC Audit of BCAP ERC 84-101 9/11-12/84 Meeting Attendance
- Name:
Organization:
- M. R. Dougherty BCAP R. M. Pokorn CECO R. L. Byers BCAP C. M. Thompson ERC J. E. Young-ERC A. E. Cocoros ERC
- R. E. Spence BCAP
- R. N. Gardner NRC
- Post Audit Mtg. Only 9
I 131
r.
~
EVALUATION RESEARCH CORPORATION QUALITY ASSURANCE AUDIT REPORT Audit No's: ERC 84-102 Dates: 9/18 - 27/84 I. Audit Scope To evaluate the adequacy and implementation of the BCAP Admin-istrative Procedures, BCAP-01 thru 3 CAP-08, in accordance with the requircaents of BCAP Program Plan dated June 1984. ..
I I. Audit Team J. E. Young - Teaa Leader C. ft. Thompson - Team Member J. E. Hoff - Team Member
. III. Personnel Contacted M. R. Dougherty 1,2,3 BCAP M. L. k!illiams 1,2,3 BCAP R. L. Bycrs 1 BCAP L. S. t!eiss 1,2 BCAP M. K layman 1 BCAP M. A. Clinton 2,3 BCAP R. M. Pokorn 3 Ceco V. A. Hoffman 3 BCAP R. E. Ham 3 IE0G ft . N. Kaushal 2,3 BCAP G. M. Orlov 2,3 BCAP J. C. Thompson 2 BCAP N. Szabat 2 BCAP il0TE: 1 - Indicates attendance at Pre-Audit Conference 2 - Contacted during audit.
3 - Indicates attendance at Post Audit Conference.
132
IV. Summary of Audit Results As a result of the audit, four (4) Audit Action Requests (AAR's) and (1) concern were issued. These were issued in the area of Qualification and Certification of Reinspection Personnel. One (1) comment was stated in the area of BCAP Interface With Contractors And Architect Engineers.
The following is a surmary of the criteria audited, including audit findings and concerns:
A. 8 CAP-01, " Program Indoctrination for Employees" At the time of the audit, the Audit Team had not been issued Revision One (1) of BCAP-01.
The checklist for Rev. O, and a copy of of Proceo'ure BCAP-01 Rev. I was utilized to verify implementation. This area considered satisfactory. -
- 8. BCAP-02, " Organization & Responsibility" This area was not reviewed during this audit.
The effectiveness will be evaluated during a subsequent audit.
C. BCAP-03, " Records Management" This area was not reviewed during the audit due to ,
personnel being unavailable. This will be reviewed during a subsequent audit.
D. BCAP-04, "SCAP Interface with Contractors and Architect /
Engineer" During the audit, it was noted that Document Request Logs were found to be in various stages of completion. The following comment was discussed during the Post Audit Conference:
It was observed that many procedural steps relating to the Document Request Forms were not being followed. This procedure should be reviewed to determine if those steps are necessary.
This comment is stated for consideration only and does not require a response.
E. 8 CAP-06 " Observation and Discrepancy / Concern Processing" During the audit three (3) observations had been prepared and are entered into the i4APPER System. The observations had not been processed any further, therefore, verification of implementation will continue during a subsequent audit.
133
-- .. l l
F. BCAP-07, "BCAP Reports" i The time.
Audit Team elected not to review this area at this This will be evaluated in conjunction with BCAP-03.
G. SCAP-08, " Qualification and Certification of Reinspection Personnel" At the time of the audit, no inspectors had been certified. However, during the review, four (4) Audit Action Requests (AAR's),and one (1) concern were issued. These are identified as follows:
AAR #84-102-1: The indcctrination exams taken by individuals to be certified as Level III had also been approved by these same individuals.
Prior to the Post-Audit Meeting on 9/27/84, was '
verified that a new indoctrination exam has been developed and approved by the BCAP Inspection Supervisor in accordance with BCAP-08. The potential Level III's have been re-examined, therefore, '
this finding is considered to be resolved.
AAR #84-102-3: Training Lesson Plans were approved by individuals as Level III Inspection Leads who were -
not yet certified to BCAP-08.
AAR #84-102-4: SCAP-08, Appendix V,Section II, requires a forty (40) question area exam. During the audit, a review of exam banks indicated there were no area exams.
Concern 1: During the review of three (3) inspection personnel packages who were scheduled for certification, it was noted that one of the inspectors did not meet the Education / Experience Requirements of N45.2.6.
The requirement states that with a high school
' education, a person must have "three (3) years experience in Quality Testin ivities, or one (g1) and/or Inspectionperformance year satisfactory or related act- as a Level I. .
The i ndividual, K. Daniels, has a high school education and only twenty-one (21) months experience. The records did not indicate certification to Level I as a substitute for years of experience.
i l
134 1
- - , - . - .. . , - - - - - - - -eg,,-e-,,,,-,,,..wg n_y ---,-.m .,,- ,,,-.,-mm-,-.--,, ._m-.- - - , - - - ,-,.-..,n. - ,,~,,e,ve~. -
V. Effectiveness Within the scope of the audit, the implementation of BCAP Administrative Procedures, BCAP-01 thru SCAP-08, appears
, to be adequate, except as noted on the attached Audit Action Requests.
VI. Attachment
~
AAR #84-102-1 AAR i84-102-2 AAR #S4-102-3 AAR #84-102-4 b V' 4 #f>f
'AUDITpAl-1LEADEly
$ focolos f9s QUALITYASSURANCEMpAGER}
135
EVAL UATION RESEARCH .
AUDIT ACTION REQUEST COR PORATIO N
- 84-102-1
- 1. COMP ANY/ AC TIvlT Y Commonwealth Edison Company 2. REPOnT NO. ERC 84-102 Braidwood Construction Assessment Program oATE 9/27/84 Y E. Youno S N
.P52 lint *
- s. RESPONSIBLE MANAG'ER N. Kaushal [ [ 6. LOCATION painenactinn Qual. & Cert.
parennnoi of
- B N b N v. O Para. 3.2 E
- 8. FINDING PAGE 1 OF Requirement: " Newly-assigned reinspection personnel shall complete required indoctrination & training prior to performing quality related activites. Indoctrination includes a closed book written examination containing at least
~
(10) questions ...."
Finding: The indoctrination exams taken by E. Shevlin & D. Burlison on 8/22/84 had also been approved by these same individual s en the BCAP Inspection Test Approval Sheet on 8/9/84.
REPLY REQUESTED BY: Detnhor 17 lord DA TE
- 9. REPLY REPLY PAGE I OF CAUSE:
ACTION TAKEN TO CORRECT:
ACTION TO PREVENT RECURRENCE:
DATE FOR FULL COMPLfANCE: .
RESPONStut.E REPRESENTA TIVE DA TE
- 10. VEniflC A TiOtJ REPLY CY A00nEssEE :s sATisFACTOnY - - .
_, , _ , ,A UDITOR ,
DA Tc, ACTIOf4 TAKEfJ es sATisrACTOnY -
A UDITOR DA TE Of-18.1.3 8/84 136 _
g e veuxi a veu
, ". RESEARCH .. AUDIT ACTI.0i1 REQUEST COR PO RATI O N
- 84-102.-2
- 1. COMPANYt ACTIVITY Commonwea lth Ed ison Company 2. REPORT NO. ERC 84-102 .
Braidwood Construction Assessment
- Prooram DATE 9/27/84
.- [h.Youno N. d . -- -- - -1 27/[g A0yj$nto g, S5
- 5. RESPONs18LE MANAGE'R / / 6. LOCATION Qual. & Gert.. Or N. Kaushal / Reinspection Personnel
- 7. REQUIREMENT .
8 CAP-08 Rev.0 Pa ra 3.11.'1
- 8. FINDING PAGE 1 OF -
Requirement: Questions will be reviewed and approved by applicable Level III Inspection. Lead, Certification / Training Administrator and a Ceco QA representative prior to being included in the examination banks. Examination banks shall include a minimum of eighty ques,'tions." ,,"
Finding: At the time of the review, only (71) questions exist in a BCAP General Exam Bank. Also, the questions were reviewed & approved by E. Shevlin & D. Burlison who were
~
- not certified Level III Inspection Leads.
1 .
REPLY REQUESTED BY: October 12, 1984 -
- 9. REPLY REPt.Y PAGE 1 OF CAUSE:
ACTION TAKEN TO CORRECT:
- l I
ACTION TO PREVENT RECURRENCE:
i OATE FOR FULL. COMPLIANCE: .
RESPONS10L E REPRESENTA TsvE DA TE
- 10. VERIFIC A TION -
4 REPt.Y oY A00nESsEE 15 s ATISFACTonY Auctran oni ACTION TAN:Ett IS sATISFACTOnY -
AvorrDa os rE ;
QF.la, g ,3 gfg4
.137
- - n - ,om--, _ e- - - , -
,m, -,-.,, - ~ ,,_ ,. r - - _ - - - - - - - . - , , - - - . - - , , - - -. , - - , - - - - , , - - - - - , . - - - . - - , _ , . - - - - - , - - -
EVAt_U ATI O N RESEARCH ..
AUDIT ACTION REQUEST C O R P O R A"T*l O N , g-3
- 1. COMP ANYt ACTivlTY 2. nEPORT NO. ERC 84- 102 Commonwealth Edison Company Braidwood Construction Assessment Prooram OATE g/27/84 .
o~ '$."$'.* oung 0 f $fy_- 4 br/r/ '
h.'c$' ton S. RESPONS18LE MANAdER N. Kaushal
/ / 6. LOCATION Qua l . & Cert, of Reinspection Personnel
, 7. REQUIREMENT ;
BCAP-08 Rev. O Para 3.13
- 8. FINDING PAGE 1 OF
- Requirement: " Training Lesson Plant will be reviewed & approved by the applicable Level III Inspection Lead, ..."
Finding: Training Lesson Plans were approved by D. Burlison, J. Sexton & E. Shevlin, who were not certified Level III Inspection Leads.
REPLY REQUESTEC GY:
October 12, 1984 OA TE
- 9. REPLY REPt.Y PAGE 1 OF CAUSE:
ACTION TAKEN TO CORRECT: .
ACTION TO PREVENT RECURRENCE:
DATE FOR FULL COMPLIANCE: .
RESPONSIBL E REPRESENTA TIVE DA TE to. VERIFIC A TlON .-
FMLY 3Y ACCP.50T.!!:s C AT;; AC;O3Y -
A UDITOR OA TE ACTION TA8:EN IS SAidFACTOny .
A UDITOR DA TE QF.18.1.3 8/8,; 138
1
~~
. EVA L.LJ ATI O N RESEARCH -
AUDIT ACT10i1 REQUEST l COR P O RATI O N
- 84-102-4 i
l
- 1. COMPANY / ACTivlT Y 2. REPORT NO. ERC 84-102 ;
Commonwealth Edison Company :
Braidwood Construction Assessment procram DATE 9/27/84
' N [. Young O _ d her. q 9/;27/p</
'8. inTo N .
- 5. RESPONSIBLE MANA'GER N. Kaushal / / 6. LOCATION Qua l . & Cer t . of painsnaction Personnel
- 7. REQUIREMENT BCAP-08 Rev.0 Appendix V
- 8. FINDING PAGE 1 OF Requirement: Appendix V, Section'll, requires that a minimum (40) questions, closed book, area exam shall be given for l certification of Level II Inspection Personnel Finding: During the audit, a review of exam bards indicited there were no area exams.
I a
REPLY REQUESTED BY: netnhor 19. lord DA TE
- 9. REPLY REPLY PAGE 10F CAUSE: ,
ACTION TAKEN TO CORRECT:
ACTION TO PREVENT RECURRENCE:
DATE FOR FULL COMPLlANCE: .
. RESPONSIBL E REPRESENTA TIVE DA TE t
to, vCRIFIC A TsON
- nEPLY OY AOonESSEE IS SATISFACTORY
- Avolvon oa it Of-18.1.3 8/n4 139 0 -
-