ML20127D741

Rev 2 to QA Plan,Braidwood Const Assessment Program (Bcap). Related Documents Encl

ML20127D741
Person / Time
Site:	Braidwood
Issue date:	11/02/1984
From:	Hansel J EVALUATION RESEARCH CORP.
To:
Shared Package
ML20127D681	List: ML20127D677 ML20127D708 ML20127D741
References
BCAP-001, BCAP-1, NUDOCS 8506240320
Download: ML20127D741 (53)

Text

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A Doc. No. -

BCAP 001

, Rev. 2 EVALUATION RESEARCH CORPORATION QUALITY ASSURANCE PLAN BRAIDWOOD CONSTRUCTION ASSESSMENT PROGRAM (BCAP)

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Approved by f  % -t# Date II 7- [ 8 Y John L. Hanse't -

8506240320 850219 102 PDR ADOCK 05000456 R. PDR

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v BCAP 001 Rev. 2

SUMMARY

OF REVISIONS l

DATE REY. REVISION 8/10/84 1 Section 1, paragraph 1.1, page 4. Identifled the Team Leader for QA and Audits as the individual responsible for inspection and auditing of BCAP activities.

8/10/84 1 Section 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 nmes from chart.

8/10/84 1 Section 1, Figure 1.1-2, page 6. ERC/BCAP Organiza-tional Structure - removed proper names from chart.

0 8/10/84 1 Section 1,. paragraph 1.3, page 7. Identi fled training of BCAP Project personnel as the QA Manager's responsi-

!. bility.

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 resp 5nsibility of the-QA Manager to perform periodic internal audtts of the BCAP Task Team.

11/02/84 2 Corrected Table of Contents to reflect actual page nianbers.

11/02/84 2 Section 1, Figures 1.1-1 and 1.1-2, pages 5 and 6 were corrected to show the reporting level of the QA Manager.

11/02/84 2 Table 2.1-1, page 10, item no.10, corrected title of QAP-10.2.

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i BCAP 001 Rev. 2 TABLE OF CONTENTS -

Page  ;

0.0 Introduction ...................... 1 i

1.0 Organization and Responsibilities . . . . . . . . . . . . 3 1.1 Proj ec t Org ani zati on . . . . . . . . . . . . . . . . 3 1.2 Responsibility of Project Manager. . . . . . . . . . 4 1

1.3 Quality Assurance Manager. . . . . . . . . . . . . . .7 l

1.4 Quali fication Requi rements . . . . . . . . . . . . . 7 2.0 Qu al i ty Assuranc e P rog r am . . . . . . . . . . . . . . . . 8 2.1 Quali ty Assurance Pl an . . . . . . . . . . . . . . . 8 1

2.2 Personnel Quali fications . . . . . . . . . . . . . . 9 2.3 Tr ai ni n g . . . . . . . . . . . . . . . . . . . . . . :12 t 3.0 De si g n Cont rol . . . . . . . . . . . . . . . . . . .

.. 12

4.0 Procurement Document Control .............. 12

5.0 Instructions, Procedures, and Drawings . . . . ... . . . 13 -

S 6.0 Doc ume n t Co n t rol . . . . . . . . . . . . . ....... 13 7.0 Control of Purchased Material, Equipment, and Services. . 14 8.0 Identification and Control of Materials, Parts, and Components . . . . . . ................. 15 9.0 Control of Special Processes .............. 15 10.0 Inspection ........................ 16 i

-11.0 Test Control ....................... 16 12.0 Control of Measuring and Test Equi pment . . . . . . . . . .16 13.0 Handling, Storage, and Shipping . . . . . . . . . . . . . 17 14.0 Inspection, Test,- and Operating Status . . . .~. .'... .

17 15.0 Nonconforming Materials, Parts, or Components . . . . . . 17 i

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BCAP 001 Rev. 2 TABLE OF CONTENTS (continued)

Pay 16.0 Co rrec ti ve Ac ti on . . . . . . . . . . . . . . . . . . . . 17

17.0 Quali ty Assurance Records . . . . . . . . . . . . . . . . 18 18.0 Audits . . . . . . . . . . . . . . . . . ........ 19 Appendix I ........................... 23 m

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d BCAP 001 3

Rev. 2 LIST OF ILLUSTRATIONS o

s Pg 1.1-1 ERC/BCAP Organi zational Chart . . . . . . . . . . . . . . 5 2

1.1-2 ERC/8 CAP Organizational Structure . . . . . . . . . . . . 6  ;

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LIST OF TABLES 2.1-1 BCAP Quality Assurance Program Index .......... 10 2 I

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BCAP 001 Rev. 2

0.0 INTRODUCTION

This Quality Assurance Plan describes the Quality Assurance Program which the ERC Independent Expert Overview Group will apply to the scope of work for the Connonwealth 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 program 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 document objectives and a review of each of the BCAP elements. Determining if the, BCAP elements will fulfill the objectives.

O 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 107

BCAP 001.

-- Rev. 2 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 perfomed and doctamented.

o Preparing in-depth audit reports.

o Preparing periodic status reports and a final report sisamarizing their overview activities and simnary 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 ntsaber 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 4

is for this reason that they will not be addressed in this plan.

The Overview Group will be required to perform certain tasks that come f under the purvie s a 10 CFR Part 50, Appendix B, i.e., audits, inspections, i

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BCAP 001 Rev. 2 training, records management, etc. This Quality Assurance P1an 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 tean of experts whose purpose will be to pro-vide an independent overview of the BCAP. ERC has formed thi.s 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 Independeat Expert Overview Group members will be free of any significant contacts with Commonwealth 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-ployed 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 Cosunonwealth Edison Company or a Braidwood site contractor which exceeds 5% of the family annual income.

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BCAP 001 Rev. 2 The Overview Group bdll conduct a comprehensive third-party overview of the BCAP, 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 tdll be responsible for assuring that tests, inspections, examinations, and audits conducted in conjunction 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 comunicate with Comonwealth Edison through a designated Connonwealth 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 110

EVALUATION WESEARCH Ceco COWPOWATIO N MANAGER OF PROJECTS ERC PROJECT MANAGER QUALITY ASSURANCE ASSISTANT PROJECT MANAGER D-ADMINISTRATION I I I I AND IPING L '^ ^ OA & AUDITS STRUC URAL

?E FIGURE 1.1-1. ERC/BCAP ORGANIZATIONAL CHART  %

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IEVALUATION '

TESEATCH CECO CORPOWATION MANAGER OF PROJECTS l

ERC PROJECT MANAGER QUALITY ASSURANCE ASSISTANT l PROJECT MANAGER g ADMINISTRATION

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AND 1 PING ELECTRICAL HVAC STRUC URAL QA & AUDITS CSR S

p METHODOLOGY C P

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7 o FIGURE 1.1-2. ERC/BCAP ORGANIZATIONAL STRUCTURE

l BCAP 001 Rev. 2 .

Chairman of the Board df CECO. The ERC Project Manager will regularly

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report to the Manager of Projects regarding the effectiveness of the BCAP l program.

1.3 QUALITY ASSilRANCE 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 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 Pl an. The QA Manager shall also assure that ERC personnel assigned to BCAP are indoctrinated, trained, and certified, as required, in accordance with applicable procedures.

1.4 QUALIFICATION REQUIREMENTS The Quality Assurance Manager shall have the following minimum quali-fic ations:

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BCAP 001 Rev. 2

1. Shall have either a B. A. or B.S. degree or equivalent.

2. Shall have a minimtm of 10 years experience, with at least 5. years of supervisory experience, in quality assurance, engineering, manufacturing and procurement, or combination thereof, associated 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 Vessel Code. He shall have a working knowledge and understanding of quality assurance methods and their application.

4. Shall be experienced in organizing, directing, and administering an overall program or activity, or a major portion of an overall program having broad sc6pe and application.

2.0 QUALITY ASSURANCE PROGRAM 2.1 OVALITY ASSURANCE PLAN This Quality _ Assurance Plan recognizes the need to establish and im-pienent a Quality Assurance Program 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 114

BCAP 001 Rev. 2 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 that compliance with the Quality Assurance Plan is mandatory. The Plan is maintained and controlled by the Quality Assurance Manager tnd is reviewed at least annually and modifed as necessary to keep it current and up-to-date.

2.2 PERSONNEL QUALIFICATIONS ERC determines the initial capabilities of employees and contract per-sonnel (hereafter referred to as employees) 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 doctmented annually through management assess-ments, which includes proficiency testing where appropriate.

During the BCAP program, ERC bdll 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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BCAP 001 Rev. 2 TABLE 2.1-1 BCAP QUALITY ASSURANCE PROGRAM INDEX Quality Elements Implementing Procedures and Titles 4

1. ORGANIZATION QAP-1.1 Personnel Qualifications (10CFR50, Criterion f!) QAP-1.2 Indoctrination and Training of Personnel

2. QUALITY ASSURANCE PROGRAM DP&P-101 Quality Assurance Policy (10CFR50, Criterion fII)

3. DESIGN CONTROL N/A (10CFR50, Criterion #111)

4. PROCUREMENT DOCUMENT CONTROL QAP-4.1 Procurement Doctment Control (10CFR50, Criterion flV)

5. INSTRUCTIONS,'ROCEDURES P & 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 fVI) of Quality Assurance Docu-

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ments

7. CONTROL OF PURCHASED MATERIAL, N/A EQUIPMENT, AND SERVICES (10CFR50, Criterion #VII)

8. IDENTIFICATION AND CONTROL OF N/A '

MATERIAL, PARTS, AND COMPONENTS (10CFR50, Criterion #VIII)

9. CONTROL OF SPECIAL PROCESSES N/A (10CFR50, Criterion #1X)

. 10. INSPECTION QAP-10.1 Quality Review and Sur-(10CFR50, Criterion #X) veillance QAP-10.2 Qualification and Certift- /2 cation of Inspection Per-sonnel h

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BCAP 001 Rev. 2

TABLE 2.1-1 (continued) a BCAP QUALITY ASSURANCE PROGRAM INDEX 1

Quality Elements Implementing Procedures and Titles

11. TEST CONTROL N/A (10CFR50, Criterion #1X) 1

12. CONTROL OF MEASURING AND N/A TEST EQUIPMENT (10CFR50, Criterion #XII)

13. HANDLING, STORAGE, AND N/A SHIPPING l

(10CFR50, Criterion #XIII)

14. INSPECTION, TEST, AND N/A OPERATING STATUS (10CFR50, Criterion fXIV)

15. NONCONFORMING MATERIAL, QAP-15.1 Documentation and Di sposi-PARTS, OR COMPONENTS tion of Observations and (10CFR50, Criterion #XV) Di screpancies

, 16. CORRECTIVE ACTION QAP-16.1 Corrective Action (10CFR50, Criterion fXVI)

17. QUALITY ASSURANCE RECORDS QAP-17.1 Quality Assurance Records (10CFR50, Criterion # XVII) Program

, 18. AUDITS QAP-18.1 Quality Assurance Audit (10CFR50,, Criterion fXVIII) Program QAP-18.2 Qualification of Audit Personnel ,

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l BCAP 001 Rev. 2 2.3 TRAINING i

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-related manuals, procedures and instructions.

3.0 DESIGN CONTROL Evaluation Research Corporation has no responsibility for design control within the Braidwocd 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 0

initiated by the cognizant ERC pa an. It is the responsibility of the requisitioner to identify the requirements and qualifications required of the contractor. The procurement document shall specify tha 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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< Rev. 2 5.0 INSTRUCTIONS, PROCEDURES, AND DRAWINGS The Quality Assurance Program provides that all activities affecting quality are to be accomplished in accordance with docuented 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 docmented as appropriate.

l Each procedure contains detailed instructions for the execution of ac-

! tivities in accordance with the approved Quality Assurance Program. Ap-proval and distribution of procedures and changes to those procedures are s

controlled by the Quality Assurance Manager. Details of measures imple-i 4

mented to control preparation, review, approval, release, change, and dis- i

tribution of procedures and instructions are described in'Section 6.0 of  ;

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i this document. When issued, procedures are mandatory for all personnel

) either performing or verifying quality-related activities for BCAP by l written directive from the ERC Quality Assurance Manager.

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j 6.0 DOCUMENT CONTROL Policy and procedure docuents for the. BCAP are subject to control .

b The measures implemented for docuent control are contained in the various j procedures of the Quality Assurance Manual. Controls are imposed for -

initial review and approval actions, release of the docuents and for dis- ,

tribution of the docuents to designated personnel who either perform or i

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BCAP 001 Rev. 2 verify quality related work to assure that they are available at the'lo-cation where the prescribed activity is performed. Revisions to these documents are reviewed and approved by the same organizations Ma approved the original docunents. These revisions are distributed in the sane manner as the initial issue.

The Quality Assurance Plan for BCAP is prepared, maintained, dis-tributed and controlled by the Quality Assurance Project Manager.

Policy and procedures docunents are either distributed to authorized manual holders or to standard distribution lists with receipt acknowledge-ment required. Distribution is controlled to assure availability of the docunents, 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 insnediate visibility to the user to assure that an obsolete issue is not followed in either perfonning 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.

i 7.0 CONTROLOFPURCHASEDMATERIAL, EQUIPMENT,ANDSEyICES As stated in Section 4.0, " PROCUREMENT DOCUMENT CONTROL", Evaluation Research Corporation's responsibility for the BCAP does not include the requirement to purchase material or equipment, however, independent con-tractors' services are contracted. The Quality Assurance Program describes 120

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controls for assuring that purchased services confom to procurement docu-4- ment requirements and that independent contractors meet the professional qualifications for the task to be assigned. These control measures -

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include, as appropriate, evaluation ;and selection of contract personnel, evaluation of contracto'r performance ' effectiveness, and examination and appraisal of docunents! generated during course of effort (reports, c

specifications, drawings, etc.). Assessments of perfomance shall be performed at interyals consistent with the importance, compiexity, and

, I 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.

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s 8.0 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS e

Evaluation Researt:h Corporation has no responsibility for identifi-cation and control of materials', parts, and components within the Braidwood Construction Assessment Program.

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9.0 CONTROL OF SPECIAL PROCESSES i .; w a .

The control of special processes such as welding, heat' treating, non-- ,

' destructive examination, cleaning, bonding, coating, hidering, plating and

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hard surfacing,"is a function for which ERC has no direct responsibility within the BCAP gr'ogram. ,

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BCAP 001 Rev. 2 10.0 INSPECTION ERC has no direct responsibility for inspection activities affecting quality within the Braidwood Construction Assessment Program. However, 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.

All reinspection and document review activities and the results will be documented in accordance with applicable procedures and submitted to the Quality Assurance Manager for review and reporting to BCAP.

11.0 TEST CONTROL ERC has no direct responsibility for test control activities within the Braidwood Construction Assessment Program.

12.0 CONTROL OF MEASURING AND TEST EQUIPPENT ERC has no direct responsibility for the control of measuring and test equipment within the Braidwood Construction Assessment Program.

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3 BCAP 001 Rev. 2 13.0 HANDLING, STORAGE, AND SHIPPING ERC has no direct responsibility for handling, storage,/and shipping activities within the Braidwood Constrtstion 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 t ,  ;

, ERC has no direc[ responsibility for activities related"to noncon-

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formance, parts, or cot:rponents within the Braidwood Copstruction Assessment Program. However, nonconforning items identified by ERC during reinspec-tion and docunent review activities will be doctmented and brought to the insediate attention of BCAP,nariagement for resolution within the BCAP Quality Assurance Program.

I The Project Qualf1y As!.urance Manager shall ass $e that all noncon-

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formances identified by ERC are doctmented in accordance with BCAP pro-cedures.

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16.0 CORRECTIVE ACTION f

f ERC has no direct responsibility for corrective action activities within the Braidwood/ Construction Assessment Program. H(hever, conditions J  ? .a s,- d

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BCAP 001 Rev. 2 adverse to quality or deficiencies in the BCAP and implementing procedures which indicate that program objectives may not be fulfilled which are identi fied by ERC shall be documented.

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 gy.

Connonwealth 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 vdll be documented by the BCAP organization in a manner suitable for auditing.

Such documentation will be retained as permanent quality records as stated in the BCAP program doctment.

Those records which are necessary to document the quality assurance activities performed by ERC personnel are listed in ERC procedures along with the organizational responsibility for their collection, maintenance, storage, and retrieval .

These records shall include, but are not limited to:

o Quality Program Plans and Manuals o Procedures 124

BCAP 001 Rev. 2 o Procurement Docunents to Contractors e Personnel Qualifications o Activity Reports o Audit Packages (Plans, Reports, etc.)

o Yert fication and Evaluation Docunents 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 minimun of two (2) times which will address the implementation of each BCAP element.

Items to be specifically audited will be adherence to program procedures, evaluation of Quality Assurance involvement, qualifications of the person-nel performing inspections, and identification of nonconfonnances and adequacy of the corrective actions.

l Procedures are established and implemented for conducting these au- l l

dits. Audit plans are developed, implemented, and docunented in accordance l with these procedures. The audit teams will consist of a lead auditor qualified in accordance with ANSI 45.2.23, " Qualification of QA Program 125 l

BCAP 001 Rev. 2 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.

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 tesa leader.

o Notification of the responsible management of the work ac-tivity to be audited identifying the audit plan, team members, and audit date.

o Preparation of the documented audit checklists by the audit team and the orientation of team members by the audit team leader prior to the audit.

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BCAP 001 Rev. 2 o Conduct of audits in accordance with the prepared checklists, to include the docuentation that objective evidence was examined for compliance with QA Program requirements.

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.

o Docaentation of audit results, including critique, to the management responsible for the work audited.

o Response from the management responsible for the wrk audited indicating corrective action taken, or to be taken, to pre-ciude 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 doceented closeout of open items.

The docuentation aforementioned shall consist of a written report distributed to the BCAP Project-Manager and will contain the following information as a minimm:

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BCAP 001 Rev. 2 o Description of the audit team, the audit perfonned and the criteria used.

o The audit findings including copies of Audit Action Reports.

i 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 deftciencies 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 doctmented.

The ERC Quality Assurance Manager will audit the Task Team to verify compliance with the requirements of this Plan and the applicable imple-

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menting procedures. Audits will be conducted annually or at least once during the life of the Project, whichever is shorter.

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BCAP 001 Rev. 2 APPENDIX 1 The following ANSI Standards are used as guidelines for developing applicable ERC procedures for the BCAP program.

1. N45.2 Quality Assurance Program Requirements for Nuclear Power P1 ants

2. N45.2.6 Qualifications of Inspection, Examination 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

5. N45.2.12 Requirements for Auditing of Quality Assurance Programs for Nuclear Power P1 ants

6. N45.2.23 Qualification of Quality Assurance Program Audit Personnel for Nuclear Power P1 ants d

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a 6.5 Audit Reports Aq 130

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. FIELD OPERATIONS C

E\/AL.UATIOl\1 1755 Jefferson Davis Heghws EESEAECH suae ooo COEPOWATION ^"'aoton V"0'a'a 222o2 October 10, 1984 '""**

BCAP-043 800 Oak n.dge Turnpike Su.te 501 Commonwealth Edison Co. "*0* '*""***** 3783 Braidwood Station 5"#"

R.R. .fl. Box 81 Bracoville, IL. 60607 Attention: M r . ?! . P. Smith

Subject:

Independent Expert Overview Grcuo Audit (ERC 80-104),

conducted Oct. 2-5, 1984.

Reference:

A. E. Cocorcs to it. P. Smith, Letter - Serial #BCAP-032 Gentlemen:

This letter is to transait the report of the subjec c :1ua it announced by the referenced letter. There were three (3) cancerns discussed f during the E::it fiecting in the f cilowing arere,. Conteci of Quality

( Assurance Special Instructions, Dccumer.t Revicas, Corrective Action Recuest.

You are requested to provide a written response to the concerns within thirty (30) days from receipt of this report.

The Audit Team wishes to express its appreciation to the BCAP-QA personnel for their courtesy and cooperation during the course of the audit.

Any questions on this subject are to be addressed to the writer, extensi.on 2787.

Yours truly,

. E.7 4 4 A. E. ocores Quality Assurance l.lanager AEC:JEY/dit attach.

~ cc: T. ;la iman R . ii . Pokorn E. E. Fitzpatrick fi. Kausha l R . t! . Gardner J. G. Xeppler I,4,. .. 4 Audit Team

$[p{gy" F.i1e (2)/ 131 a.n.

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'y, hs EVALUATION RESEARCH CORPORATION 00ALITY ASSURANCE AUDIT REPORT Audit No: ERC 84-104 Dates: 10/2-5/84 I. AUDIT SCOPE To evaluate the adequacy and implementation of the BCAP-Quality Assurance Special Instruction, QASI-01 thru QASI-16 and SQl-18, 26 thru 28, in accordance with the requirements of the BCAP Program.

II. AUDIT TEAM J. E.. Young - Team Leader

'C. M. Thompson - Team Member J. E. Hoff - Team Hemoer

-W. Chase - Team Member III. PERSONNEL CONTACTED N. P. Smith 1, 2, 3 BCAP.Q.A.

W. M.-Sides 1, 2, 3- BCAP Q.A.

( J. A. Zych G. E. Cossaboom 1,

1, 2,

3 BCAP Q.A.

BCAP Q.A.

R. F. Williams 1, 2, 3 BCAP Q.A.

R. E. Spence 1, 3 BCAP Q.A.

. P. A. Lau 1, 3 BCAP Q.A.

F. Forrest 2, PTL-

. D. Stockman 2, PTL NOTE: 1-Indicates attendance at Pre-Audit Conference.

2 - Contacted during audit.

,3 -Indicates attenoance at ' Post-Audit Conference IV.

SUMMARY

OF AUDIT RESULTS As a result of the audit, three (3) concerns were issued /

discussed durinc the audit. These were issued in the areas

-of Con' trol of 00ality Assurance Special Instructions, Document Reviews, Corrective Action Request.

The following is a summcry of the criteria' audited, including the concerns:

4

-4

'r

• 132

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, _ ~

{

. Pag; 2 "

ERC 84-104

{ IV. (Continued)

A. QASI-01," Control of Quality Assurance Special Instructions" During the course of the audit, the QASI were conitored for compliance to QASI-01. During the revieu, the following concern was noted:

Concern 1: In QASI-01, Para. 5.3.3.0, it states in the

" Reference Documents" section, to list documents that contrcl or provide governing criteria for the instruction.

QASI-02, for Correction Action Requests, does not reference or take into consideration Stop Work Orders. QASI-08, Audits, does not reference CAR's, NCR's and SUO's. (It was also noted that Para. 5.6.4 does not state that NCR's will be attached to the Audit Report).

B. QASI-02 " Corrective Action Request" During the audit it was noted that fifteen (15) Corrective Action Requests (CAR's) had been written, however, only CAR-001 thru CAR-005 had been issued at this time. A revieu of CAR's indicated the following concern:

Concern 2: It was noted during the review of CAR's, that in Block 9 for " Condition Adverse to Quality", descriptions of the conditions did not include specific identification

, of docu.2ents involved, dates of occurrence or names of individuals involved (where appropriate) in the discrep-ancies. The requirement for completicn of sloc% 9 states:

" Write doun as specifically as possible uhat ycu found to be deficient...." .

C. QASI-04, " Training, Qualification and Certification of Q.A. Personnel" A re'iew v of certifications for personnel assigned to the BCAP-QA Overinspection/0vervieu Group was conducted to verify compliance to QASI-04 and SQI-18, " Orientation, Receipt Inspection and On-The-Job Training Program".

It was noted that site indoctrination / orientation had not been conpleted in accordance with the above procedures, however, this was previously identified on CAR 9002 and 006. This area was considered satisf actory.

. D. QASI-05, " Correspondence Control" This area was not reviewed during this audit.

E. QASI-06, "Docur,ent Revieus" The document review process was reviewed for compliance to QASI-06 and SQ1-28, " Document Revieu". The following

, concern was discussed during the audit:

(~. . .

- % ^,

. 133 diss)ukse.

.-mn -

- ad

. Page 3- .

., ERC 84-104

'( -

IV. (E-Continued)

Concern: The requirements in S01-28, states that

" Satisfactory completion of the review shall be indicated by so noting on the Document Review log, after incorporation of any comments has been verified". QASI-06 states that

" Commitments to make. changes to the subject document based on comments / response shall be noted on the Document Review Log, and shall not bel closed out'until the document change is. verified". During the review it was noted that there

.was no objective evidence that commitaents or document changes were verified prior to closecut.

F. QASI-07,."Surveillances" .

At the timelof the audit, one surveillance (3QAS-III-001) had been perf ormed and three were schedu led f or the following week. Surveillances were performed in accord-ance with approved Checklist. This area was considered satisfactory.

G. QASI-08, " Audits" The audit package for Audit "30AA-!Y-001 was reviewed during the audit. It was noted that the Audit Report was not issued in the time required'by Q.P. ;!o . 18-1, however, this.was1previously identified on CAR 4008. This area appears adequate at this time.

s H.- QASI-09, " Documentation / Records Contecl" At this time of the audit. verificatico packages were not completed. This area will be reviewed during a subsequent audit.

f ' '

J. QASI-10. " Interface With The BCAP Task Force" This area was not reviewed during this audit.

~

~

K. QdSI-ll, "itonthly Status Report"

, .This area was not reviewed during this audit.

LL. QASI-12. " Final Overview Report" This area was not reviewed during this audit.

M. QASI-13, "Stop Uork Order" No Stop Work Orders had been written at the time of the a ud i t '. This area will be reviewed during a subsequent

. audit.

N. -QASI-14 " Trend Analysis" No Trend Analysis had been performed to date. .This ares-

-~

will be reviewed-during a subsequent audit.

1 -

ma #

Yo * *

'I'A.. Sl;M7 134 0 0* e #g e

=

_mMun. -

M-

• " Page 4 ,-

. -, . ERC 84-104

( IV. (rontinued) -

P. QASIIS, " Sample Selection" No samples have been selected. This area will be reviewed during a subsequent audit.

R. QASI-16, " Performance of Reinspection and Document Revieu Overview" No reinspections had been performed at the time of the audit.

This area will be reviewed during a subsequent audit.

V. EFFECTIVENESS

!fithin the scope of the audit, the implementation of the GCAP

~

Q.A. Procedures, QASI-01 thru QASI-16, appears.to be. satisfactory, ,

except'.for the concerns noted above.

VI. ATTACHMENT Hone -

a s === M Auefit Team Veader

/

/

nanager oueisty assur 7 4 0 4

yAl ... ', .

. ..~ w.

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l

. FIELO OPERATIONS l

ALUATION soo ook n.co Turnpik.

suite sos PETEAUCH Ook Ridge. Tennessee 37830 COCPOWATION (615)482 7973 l

1 November 2, 1984 i BCAP-064 1

' Commonwealth Edison Company '

Braidwood Station R.R. # 1, Box 81 Braceville, IL. 60407 ATTENTION: Mr. N. Kaushal

SUBJECT:

Independent Expert Overview Group Audit (ERC 84-103),

conducted Oct. 23-24, 1984

REFERENCE:

ERC Letter No. SCAP-049, dated Oct. 18, 1984 Gentlemen:

This letter is to transmit the report of the subject audit announced by the referenced letter. There were no Audit Action Requests (AAR's) or concerns issued during the autit, therefore, no response is required.

The Audit Team wishes to express its appreciation to the BCAP

. personnel for their courtesy and cooperation during the course of the audit. The Audit Team congratulates the BCAP personnel for their thoroughness and conscientious effort in their reviews.

Any questions on this subject are to be addressed to the writer, extension 2787.

Yours truly, eb3 #

f 16(. A. E. Cocoros Quality Assurance Manager attach.

JLH:JEY/dit cc: T. Maiman i

(' R.N. Gardner

'^ J. G. Keppler l _

IEOG Team f (2) FilesV l

136 e

EVALUATION RESEARCH CORPORATION QUALITY ASSURANCE AUDIT REPORT

(: .

Audit No: ERC 84-103 Datest 10/23-24/84 I. AUDIT SCOPE To evaluate the adequacy and implementation of the RPSR Procedures BCAP-41, 42 & 43 in accordance with the requirements of the BCAP Program.

II. AUDIT TEAM J. E. Young - Team Leader W. L. Chase -

Team Member III. PERSONNEL CONTACTED H. L. Vener 1,2,3 BCAP G. M. Orlov 1, 3 BCAP V. A. Hoffman 1, 3 BCAP A. P. Amoruso 1, 2, 3 BCAP

( M. R. Moderski V. J. Turner N. N. Kaushal 1, 2, 3 1, 2, 3 3

BCAP BCAP BCAP

) W. A. Matson 3 SWEC E. J. Siskin 3 SWEC Note: 1-Indicates attendance at Pre-Audit Conference.

2-Contacted during audit.

3-Indicates attendance at Post-Audit Conferen~ce.

IV.

SUMMARY

OF AUDIT RESULTS As a result of the Audit, no Audit Action Requests (AAR's) or concerns were issued. The following is a summary of the criteria audited.

A. BCAP-4.1, "RPSR-Identification of Specifications and Contractor Procedures" The RPSR Team has identified approximately nine (9) safety related spec's that.were effective on the 6/30/84 date. _The review is ongoin the exact number of active. spec's. g Also to determine the review is considering the unincorporated ECN's for addition to.the tabulation of specifications. LThis area is considered satisfactory.

(

a

'137

• \

B. BCAP-42, "RPSR-Prepa ra t ion of CNRck li s t s" The Audit Team verified that a review list has been completed for Chapter 8 - Electrical - of

~{ the FSAR. All chapters have not been completed at this time. A generic checklist is being pre-pared for each contractor for personnel qualifications and certification requirements.

The RPSR Team has not compared the'FSAR Review List and the Requirement / Procedure Checklist at this time. This area is considered satisfactory.

C. BCAP-43, "RPSR-Review of Contractor Procedures" This area was not reviewed during the audit due to no work completed. This area will be reviewed during a subsequent audit.

V. EFFECTIVENESS Within the scope of the audit, the implementation of the RPSR Procedures BCAP-41 thru 43 is considered satisfactory. '

IV. ATTACHMENT None

(

T AtJ&l l T E Abp E ADER /

D[ /

Quality Assurance anag

(.  %

138

' .r FIELD OPERATIONS EVALUATION soo oak n.oo. Turnpiwe WESEAECH ssie soi COEPOWATION O*" "' age. Tennessee 3783o (615)482 7973 October 30, 1984 BCAP-058 Commonwealth Edison Company Braidwood Station R.R. #1, Box Bi Braceville, IL. 60407 Attention: Mr. N. Kaushai c

Subject:

Independent Expert Overview Group Audit (ERC 84-105)

Conducted October 16-19, 1984.

Referenca: A. E. Cocoros to N. Kaushal, letter Serial rSCAP-039, dated October 8, 1984.

{ Gentlemen:

This letter is to transmit the report of the subject audit announced by the referenced letter. There were no Audit Action Requests (AAR's) or concerns issuec during the audit, therefore, a response to this raport is not required.

The Audit Tea.;. wishes to express its appreciation to the BCAP personnel for their courtesy and cooperation during the course of of the audit.

Any questions on this subject are to be addressed to the writer, extension 2787.

Yours truly,

,Q,_A . E. C tr e /[

oros Quality Assurance Manager attach. -

AEC:JEY/dlt ".

cc: T. Mai. nan .

R. N. Gardner .

• t J. G. Xeppler *

( IE0G Team (2) Files /

139

'mm sa w . w m.v.:5 fr% zw ~ **

• EVALUATION RESEARCH CORPORATION QUALITY ASSURANCE AUDIT REPORT Audit No: ERC 84-105 Dates: 10/16-19/84 I. AUDIT SCOPE To evaluate the' adequacy and implementation of the CSR Procedures,-BCAP-20 thru 24, in accordance with the requirements of BCAP Program Plan dated June, 1984.

II. AUDIT TEAM J. E. Younc - Team Leader C. M. Thompson Team Member W. L. Chase - Team Member III. PERSONNEL CONTACTED A. A. Patterson 3

'L. S. Weiss 1. 2, 3 G. M. Orlov 1,2,3 V. A. Hoffman 1, 2 , . 3

( H.

N.

L. Vener N. Kaushal 1, 2, 3 3

P. Mule' 1, 2, J. C. Thompson 1, C. Sward 1, 2 ,

R. Baumgarten 1, 2,

• L. R. Duss 1, D. J. Patel 1, NOTE: 1-Indicates attendance at Pre-Audit Conference.

2-Contacted during audit.

3-Indicates attendance at Post Audit Conference.

IV.

SUMMARY

OF AUDIT RESULTS As a result of the audit, no Audit Action Request (AAR's) or concern's were issued during the audit.

The following is'a summary of the criteria. audited.:

~

A. BCAP-20, "CSR-Establish Populations" The areas of HVAC Hangers & Duct, and C'oncrete Placements were reviewed during the audit for . .' -

population establ.ishment. List ha.d been received

• from the oppropriate contractors with statements .

• (, , attesting that these reports consist of all safety-related, inspected and Q.C. accepted items.

.. 140

-a m 3 . ...< :n ....

(- B. BCAP-21, "CSR-Sample Selection" At the time of the audit, no biased samples had been selected. Random samples-of (60) had been selected for Duct. Hangers & Concrete Placements from a computerized random number list.

C. BCAP-22, "CSR-Preparation of Instructions and Checklists" Checklist and Instructions had been developed for Duct. Hangers and Concrete Placements for rein-spections. No Documentation Review Checklist had been developed at the time of the audit. During the review of the instructions, it was noted that included were specific details, accept / reject criteria and generic instructions as applicable. .

D. BCAP-23, "CSR-Preparation of Reinspection and Document Review Packagrs" The reinpection packages reviewed contained unique package numbers and the required documents included.

During the review of package CSR-1-H-03-003, the following was noted:

Concern: The checklist listed for attachments, drawings M-1261-5, Rev. J and M-1261-6, 7 Rev. M but excluded FCR's L-13410 and L-13412. Drawings M-1261-5, Rev. K and M-1261-6, Rev. N were included in the package.

A review of this discrepancy was conducted and the checklist revised to show the .

latest revision. The review included impact study for items completed. It was noted that the later drawings incor-porated the above FCR's, therefore, had no effect on inspections previously per--

formed. This item is considered corrected and closed. No response is required.

E. BCAP-24, " Performance.of Reinspection & Document -

Review" Reinspections have been preformed in accordance with appropriate Instructions and Checklists with observations documented on the index. Observations have been processed in accordance with Procedure BCAP-06. 'This area is considered satisfactory. .

(%e .

4

~

141

(- V. EFFECTIVENESS

' Within the scope of the audit, the implementation of the CSR Procedures BCAP-20 thru 24 is considered satisfactory.

BCAP-25 was not issued at the time of the audit, '

therefore, will be reviewed during a subsequent audit.

VI. ATTACHMENT None W E.% 9 AUD11 TEAb%EADER /

(

QUALITY ASSURAt:CE e AGER 4

4 6

4

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4

, 9 8

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142 e' l_ _ _ _T_ T*:lL _  ? _ _ _'_*L - _ _ LL- _- _ -- - _-- _- - - _ -_ - - --_ -. __-- --- - - - -- ----- - . --- -- -----

6.6 Observations 143

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g EVALU ATION $ ,

TESEARCH '

COR PO7ATIO N OBSERVATIO!! REPORT

'...-:.t

,,,, ,,, ..

, " u.Ob servati on flo. BC AP - OG s -co q Date i t> - M - 8 y To: M. Raushal From: ERC Project Manager.

BCAP Director h f M A _ b 3l M e oJ __LO-3(-At/

Signature Date Observation: I. w % e r e. tw $pe c.to t' n proc. e55 , Se vera.1 'm shnc e3 hAye occ or red re ceWMy whiik gewe cche 5 cowceen tu tYbiw 4ht They T EOC, are as f tgav-d bllotost$g  : % adt q ua cy o f M fe t vtSpedte's {Res:

t) WLN observ inq a reInspecitow , it taas noted +hai iteus nai ow he. drAwth gs teethq used for reinspedsow werd documented ik h"7.4 % M"C.duen and noi as close< vadions , They toeg up gradecl % "Otose evdiin3" aMee promptke 1o, ik 4(2c And. lE0' Signature of Orignator Date RFhw toisih y Response (Requested within 30 days of above date.):

See DO Observatic: BOAF-03S-001. Attach. ent.

Date BCAP N. N. l Oirector & \ \ {M IVf

~

Response is [ Acceptable Unacceptable m -

RCA flo. Issued Signature u b-7 Mhq( Date \l/25/Ay ERC Pro [cht Manager QF-15.1.1 8/84 144 Page 1 of 2.

.~

2.) A b%ie ( Levet lu_ Jaspeder, vvWils overvtewi% resu(h of c. Levet IE_ inspedor, o nc ov e red discrepawc'ies prevEosk overlooked lo g 4ke Le v el U_ .

4 DocJwg a reviiw of t s R. Conc rete Plac e twegit Package.

rdo , c_srt-T__s - o t-z i , ir vaa s noteci 4at { tv < em(oeds we re nd ndecl os loetbg mspeded ow dra.w tng E35' Eur h Reader Al % peoct uall E.1evdion Far 6id(

t Grea. 1 i s.

4) the level of o.dddtoraj dtscrcpawcies onc ov ered to y PTt_ ov er tbspec.M,a o.{+ec Do wie i \nal c_o got eted

% e. tn M i reinspec. ban.

Evex 4 bough 4'be re 't n s p eciton p ro$ ra.w ha s onl y recenil beew (n'd {a.keci , 4k e (m'qb twc(deuce o k %e. occurrenc es oudtw e ck ob ove .t's Soh9s'ctini b c)e h t e d e. a C_ owc e rn dik he 1T06. Tt ~t s Cequesied 'Yhd BCA 9 resgencl wIh Otir bo.s't 5 kor b4 O.hre.wstwk ibn ec5 (he tu5 cmd id.enkiE sg (oha. COCfeci(YW QChLon5 toib be (bc or pora,he 6 C_oW w 00. Mc e .

'ro DQ$cNe 145 Q$t O 1 i l

l BCAP-CBS-C04

.nsuunment to BCAP-OBS-004 Response to IEOG Observation BCAP-OBS-004.

1. Observation / Concern "While observing a reinspection, it was noted that items not on th'e drawings being used for reinspection were documented in the " Remark's" column and not as observations. They were upgraded to " Observations" after prompting by the NRC and IEOG".

Response / Corrective Action The item in question is assumed to be the same embedded plate issue addressed in BCAP-OBS-003. The response to BCAP-OBS-003 addresses the evaluation and corrective action taken for this item.

2. Observation / Concern "A Daniel Level III Inspector, while overviewing results of a Level II Inspector, uncovered discrepancies previously overlooked by the Level II."

Response / Corrective Action Actually there were two occurrences of this situation at the time of the ERC surveillance. One resulted from a planned overinspection in the Civil discipline and the other was identified during a special overinspection in the M/W discipline requested by CSR Engineering..

A. The item in the Civil discipline involved an embedded plate which was shown on the package vendor drawing as a continuous plate. Actually two separate plates had been placed very close end to end. The verification package instruction does not specifically " key" the inspector to look for this condition nor to consider it rejectable. There was however a general CSR Engineering instruction and understanding to note such conditions in the remarks for further engineering evaluation.

The Level III Inspector noted the condition in a planned overinspection.

b" ~p4(64 (0524J) 146

B. The item in the Mechanical / Weld area involved a subjective welding call and a disorientation problem in describing a correctly identified weld condition.

Training sessions with the involved Level II Inspectors were held and documented soon after these conditions were noted by the Level III Inspectors.

3. observation / Concern "During a review of CSR Concrete Placement Package No. CSR-I-S-01-21, it was noted that five embeds were not noted as being inspected on drawing E357 for the Reactor Pool Support Wall Elevation Far Side Area 7 & 8."

Response

Five (5) embedded plates grouped together at the west end of the north face were inadvertently overlooked. These plates have since been reinspected and found satisfactory.

Corrective Action There were three (3) specific corrective steps taken to address this concern:

1. An independent completeness check was performed by the Civil / Structural Level III Inspector on all prior packages inspected by the affected Level 11 reinspection team exclusive of those that had been previously overviewed or inspected by the Discipline Level III ERC, or BCAP QA. Six packages were checked for inspection completeness for attributes such as formed openings, embedded plates and general surface conditions. No items or area of inspection incompleteness were observed by the Level III Inspector which supports a conclusion that the missed 5 plates were an isolated case as opposed to a generic laxity by the inspection team.

2. An instruction session was held with the inspectors involved. It was stressed that should any future package be considered confusing in anyway as to either the items or areas to be reinspected these conditions will be discussed with the Lead Inspector to determine whether additional information should be obtained from CSR Engineering. It was also stressed that care must be taken to ensure that all items within any package must be complete prior to final sign off by the inspectors of the applicable checklists.

(>$ Y (0524J) 147

m  ;

4

3. As an extra measure to avoid future confusion, Civil / structural package design drawings will be approximately marked to clearly define the boundaries of the structure / item that is to be reinspected.

4. Observation / Concern

• The level of additional discrepancies uncovered by PTL overinspection after Daniel had completed the initial reinspection."

Response

Preliminary evaluation of BCAP Q.A. overinspection results on 6 packages shows a high level of agreement with Task Force ident_ified observations within the scope of the package reinspection instructions. The additional discrepancies identified by PTL overinspections %ere taostly in the area of subjective welding-related inspections.

Corrective Action Procedure BCAP-30 " Evaluation of Overinspection Results" is being written to evaluate differences in the results of the BCAP inspections and those of the BCAP QA overinspections.. Those differences attributable to BCAP inspector error will be identified. The error rate for each BCAP inspector will be calculated and compared with predetermined acceptance standards. Appropriate corrective actions will be taken for inspection personnel whose performance does not meet these acceptance standards.

Procedure completion is projected for 12/1~1/84.

e v <. A em s

(0524J) 148

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EVALU ATIO N {l ,.. .  % [*ylf .

VESEARCH '

CO7PORATIO N OBSERVAT!0ft REPORT TC/ 21 E .!

Otiservation Ha. _BCAP-0BS-003

, u a C. . . u.s R. .. . g, t., ,,, ,

Date 10/24/84

~

To: From: ERC Project Manager <

BCAP Director ,

7 9 % ew SLd% u( ioA %y Stknature Date Observation: As the result of a surveillance performed by IEOG personnel on October 16, 1984, the folloying observation was made. During the reinspection of Verification Package CSR-I-S-01-09, an embedded plate located approx.10' south of column 20 on the west face of L line wall at approx. clevation 400', was found which did not appear on Sargent & Lundy design ifrawings S-SJ1 Rev. P or Southwestern , Ornamental Iron vendor .

drawing E160 Rev. 4. '

r i <

Braidwood Constructaon Assesscent Program Section IIB, page II-2 states

" Verification activities will,,be performed against the latest approved design drawings and specification requirements applicabic to Braidwood. Any apparent deviation from the design drawings and specification' requirements Signature of Orignator _ gg Date /C/25/6h Response (Requested within 30 days of above date.):

See ERC Observation BCAP-035-003 Attach =ent. ,

\

B,

?  ! ;j ..

i <

jg h j Date ef '

BCAP Director h [. /

Foe : N. N. usa./

h U* $ '

Respense is X d:ceptatic Un:cer;;:ble Nd4f/n/#(O dY /C# 474 # O/7 RC 11 o . Issued 8A7VD /f,27/F/ ,

Signature Q fM,f m ,Lw- d ( '8M Date 11,/ 2 B/A t/

ERC Project.I Manager QF-15.1.1 8/84 149 Page 1 of 2 I

BCAP-09S-003 will be documented by the inspectors / reviewers as an observation in accordance with approved procedures." The issue of identification of an observation was also addressed in BCAP Hemo #059 f rom M. A. Clinton to Discipline Lead Inspectors, "During the performance of inspection or document review, the inspector may identify an observation which is not directly related to the Verification Package in either of two ways: A condition on an item immediately adjacent to the item being inspected, or a condition on the item being inspected which is not specifically addressed by the checklist or instructions."

The discrepancy between as-built conditions, vendor drawings, and Sargent and Lundy design drawings discovered by BCAP Civil / Structural Inspectors during reinspection of Verification Package CSR-I-S-01-09 was not documented as an obse rva tion. Additionally, similar discrepancies found during the reinspection of previou's Civil / Structural Verification Packages were not documented as observations. These Verification Packages were CSR-I-S-01-3, CSR-I-S-01-4, and CSR-I-S-01-5.

These Verification Packages were recalled f rom CSR engineering and observa-tions written subsequent to the surveillance by the IEOG on Oct. 16, 1984, 150 .

I 4

Attachment

~

ERC OBSERVATION BCAP-OBS-003

?

OBSERVATION. ,

While obse'rving a reinspection, it pas noted that items not on the drawings being used for, reinspection were documented in the " Remarks" colurti and not as observa-tions.; They were upgraded do " Observations" after prompting by the NRC and the IEOG.

ANALYSIS:

The concrete placement reinspection instruction did not include clearly definitive accept / reject. criteria for the addition or deletion of embedment plates.

The sttributes of embedr.ents which are considered design significant are described by specific attributes required to be inspected"by the concrete placement reinspection instruction and the associated BCAP-22 generated inspection personnel to document the addition or deletion of embedment plates in the " Remarks" column of the checklist and mark up the package drawings to reflect the as-built condition. These as-built conditions

.were to be further evaluated by the engineering section to determine whether these conditions could be design significant.

However, based on discussions with NRC personnel, a conservative approach was taken. Observation reports were initiated on all added or deleted embedment plates identified in the checklists. This resulted in observa-tions CSR-I-S-01-3-01,-4-03,-5-03,-9-03, and 04.

Specifically, observation CSh-I-S-01-09-03 was initiated for the embedment described in the ERC observation. This embedment which is in fact identified on S&L drawing S-531, is on the turbine building side of the L-line wall and thus can be used only to support Class II structures. -

CORRECTIVE ACTION:

All conditions involving added or deleted embedments noted

~

on checklist " Remarks" sections have been identified as Observation Reports in accordance with BCAP-06. The inspection and engineering personnel involved-have been instructed to document these and similar conditions on observation reports. A revision to the concrete place-ment checklist and instructions has been completed to provide clear acceptance criteria for missing or additional embedments'.

(0520J) 151

Attachment Rev. 1 ERO OBSERVATION' BCAP-OBS-003 ANALYSIS:

The concrete placement reinspection instruction did not include clearly definitive accept / reject criteria for the addition or deletion of embedment plates.

The attributes of embedments which are considered design significant are described by specific attributes required to be inspected by the concrete placement reinspection instruction and the associated BCAP-22 generated documentation. CSR engineering personnel provided direction to the inspection personnel to document the addition or deletion of embedment plates in the

• Remarks" column of the checklist and mark up the package drawings to reflect the as-built condition. These as-built conditions were to be further evaluated by the engineering section to determine whether these conditions could be design significant.

Observation reports were initiated on all added or deleted embedment plates identified in the checklists. This resulted in observations CSR-I-S-01-3-01. CSR-1-S-01-4-03. CSR-1-5-01-5-03. CSR-I-S-01-9-03 and CSR-I-S-01-9-04.

Specifically, observation CSR-I-S-01-09-03 was initiated for the

. embedment described in the ERC observation.

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CORRECTIVE ACTION:

All conditions involving added or deleted embedments noted on checklist " Remarks" sections have been identified as Observation Reports in accordance with BCAP-06. The inspection and engineering personnel involved have been instructed to document these and similar conditions on observation reports. A revision to the concrete placement checklist and instructions has been completed to provide clear acceptance criteria for missing or additional embedments.

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Bndwood Station - ' -

A R R 1. Box 81 Braceville, IL 60407

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Telephone 815/458 2001 N'yf 2 7 7 ' '

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Nover.ber 27, 1984 BCAP Ltr. #017 Evaluation Research Corporation 800 Oak Ridge Turnpike Suite 501 Oak Ridge, Tennessee 37830 ATTENTION: Mr. J. L. lla nsel

Dear Mr. Hansel:

Our response dated November 21, 1964, to ERC Observation BCAP-OBS-003 included an attachment which inadvertently had some typographical errors. Enclosed please find a revised version which, in addition to correction of the typographical error, includes some additional changes.

Please disregard the attachment to BCAP-OBS-003 in our response dated November 21, 1984, and replace it with the one enclosed herewith (marked Rev. 1).

We regret any inconvenience to you in this respect.

Sincerely, N. N.

N. N. Kaushal BCAP Director NNK/sjs Attachment cc: BCAP File QG 69.60.2.3 R. L. Byers 153

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Attachment ,

Rev. 1 l

ERC OBSERVATION BCAP-OBS-003 ANALYSIS:

The concrete placement reinspection instruction did not include clearly definitive accept / reject criteria for the addition or deletion of embedment plates.

The attributes of embedments which are considered design significant are described by specific attributes required to be inspected by the concrete placement reinspection instruction and the associated BCAP-22 generated documentation. CSR engineering personnel provided direction to the inspection personnel to document the addition or deletion of embedment plates in the " Remarks" column of the checklist and mark up the package drawings to reflect the as-built condition. These as-built conditions were to be further evaluated by the engineering section to determine whether these conditions could be design significant.

Observation reports were initiated on all added or deleted embedment plates identified in the checklists. This resulted in observations CSR-I-S-01-3-01. CSR-I-S-01-4-03. CSR-I-S-01-5-03. CSR-I-S-01-9-03 and CSR-I-S-01-9-04.

Specifically, observation CSR-I-S-01-09-03 was initiated for the embedment described in the ERC observation.

CORRECTIVE ACTION:

All conditions involving added or deleted embedments noted on checklist " Remarks" sections have been identified as observation Reports in accordance with BCAP-06. The inspection and engineering personnel involved have been instructed to document these and similar conditions on observation reports. A revision to the concrete placement checklist and instructions has been completed to provide clear acceptance criteria for missing or additional embedments.

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