ML20134Q089

Const Assessment Program,Independent Expert Overview Group, Fourth Interim rept,Apr-June 1985

ML20134Q089
Person / Time
Site:	Braidwood
Issue date:	08/26/1985
From:	Hansel J EVALUATION RESEARCH CORP.
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ML20134Q083	List: ML20134Q079 ML20134Q089
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NUDOCS 8509090158
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EVALUATION RESEARCH CORPORATION (ERC) sRAIDWOOO CONSTRUCT!0R ASST.55NENT PROGRAM (RCAP)

IsoEPENDENT EXPERT OVERVIEW GROUP (IEOG)

FOURTM INTERIN REPORT (APRIL - JUNE. 1945) k i f 4 h[

/ John L. Hansel / 04t t e Project Manager

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I 8509090158 850821 ~

kDR ADOCK 05000456 PDR

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STATEMENT OF INDEPENDENCE This Fourth Interim Report delineates the progress and activities of the Independent Expert Overview Group (IE0G) during the period of April through June 1985 in overviewing the Braidwood Construction Assessment Program (BCAP) being conducted by Common-wealth Edison Company at the Braidwood Station.

As the Project Manager for this overview activity, I certi fy that the IE0G has continued to maintain independence from other organizations at the Braidwood Station and that the IE0G has received complete cooperation from each project participant contacted and has not been coerced by any of the parties involved.

od ./

/ J ohn L. Hansel Project Manager i

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l TABLE OF CONTENTS 1

Page 1.0 EXECUTIVE

SUMMARY

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2.0 INTRODUCTION

............................................... 4 3.0 ACTIVITIES AND ACCOMPLISHMENTS............................. 5 3.1 Staff Changes......................................... 5 3.2 Overview Activities................................... 5 3.2.1 General........................................ 5 3.2.2 Element 0verviews.............................. 5 3.3 Document Reviews...................................... 6 3.4 Overview of Construction Sample Reinspection (CSR).... 10 3.4.1 0verinspections................................ 10 3.4.2 Review of S & L Evaluations of CSR Observations................................... 13 3.5 Overview of Review of Procedures to Specification Requirements (RPSR)..................... 13 3.6 Overview of Review of Significant -

Corrective Action Programs (RSCAP).................... 14 3.7 Audits................................................ 15 3.7.1. Overview of BCAP QA Audits..................... 15 3.7.2 IE0G Conducted Audits.......................... 18 3.8 Reports of Dev'iation.................................. 1,9 3.8.1 Notices of Concern............................. 19 3.8.2 IE0G Observations.............................. 19 3.9 Issues................................................ 20 3.9.1 Status of Issues From Previous IE0G Reports.... 20 3.9.2 Issues Raised Since Last Report................ 20 3.9.3 Open Issues.................................... 21 4.0 IEOG ASSESSMENT OF BCAP.................................... 22 5.0 APPENDICES................................................. 23 5.1 Resumes............................................... 24 5.2 Training Records...................................... 32 5.3 QA/QC Qualification - Certification Records........... 41 5.4 IEOG Audit Reports.................................... 45 5.5 Reports of Deviation.................................. 49 ii

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LIST OF TABLES TABLE Page 3.1 Documents Reviewed......................................... 7 3.2 Checklists Reviewed........................................ 8,9 3.3 Verification Packages Overinsp'ected, Surveilled or Reviewed by the IE0G......................... 11,12

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, 3.4 IE0G Overview of BCAP QA Audits........................... 16,17 LIST OF FIGURES FIGURE Page 3.1 IE0G Organizational Chart.................................. 5-a 4

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I 1.0 EXECUTIVE

SUMMARY

This is the fourth in a series of interim reports which provide information on the activities of the IE0G'in overviewing BCAP. This report covers work performed during the period April 1 through June 30, 1985. Since the BCAP is in the final report phase, this will be the final interim report. The IE0G will issue a final report, however.

In line with maintaining appropriate staffing, the IE0G has l transferred one inspector off the project and has shifted engineering support.

The continued overview of BCAP by the IE0G has resulted in one audit concern, no audit action requests and three observations. Each of these was closed before the end of the reporting period.

During this period the IE0G reviewed 21 revisions to BCAP and BCAP QA documents and 58 CSR checklists / instructions or revisions thereto. These reviews resulted in a few comments classified as

" highly desirable" and one as " mandatory". All were cleared during the period. Additionally, the IE0G reviewed the final six completed checklists from the review of procedures by RPSR which resulted in no comments. 3 The IE0G continued its overinspection of selected CSR reinspection packages having o ve ri n s p ected some 122 packages and surveilled 16 packages while BCAP inspectors were reinspecting the hardware. In addition, IE0G inspectors reviewed 84 document review packages dealing with the documentation supporting the hardware. The IE0G overinspections resulted in three observations; the document reviews resulted in none.

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The review by the IE0G of S & L evaluations of BCAP observations for design significance increased significantly compared to the last reporting period. The IE0G has reviewed a sizeable number of the S & L evaluations. The S & L evaluations and calculations reviewed by the IE0G justify the S & L finding in those cases that none of the observations are design significant.

RPSR engineers have completed their review of the construction procedures used by all nine contractors still performing construction at the site and have delivered all nine completed checklists to the IE0G for review. The IE0G reviewed these and had no comments. Also, the RPSR engineers have written 224 observations. These are under validation review by RPSR.

These, too, will be reviewed by the IE0G.

The IE0G has continued its overview of RSCAP by personal contact, by participating as observers during a BCAP QA audit of RSCAP, and by review of checklist closeout. RSCAP has completed the review of eight of its nine significant corrective action programs and is writing final reports on these. The ninth, Quality Control Inspector Reinspection, is underway.

During this reporting period, the IE0G acted as observers during three audits conducted by BCAP QA and conducted one audit of BCAP QA. This audit resulted in one audit concern which was cleared during the audit.

This reporting period marked a notable reduction in the 3

number of reports of deviations written by the IE0G. There were no notices of concern and only three observations written. Two of I these dealt with discrepant conditions on fillet welds and the other with missing stiffeners for a junction box support not noted by the BCAP inspectors. These observations, and all previously 2

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I open observations, were closed this period. All IEOG open issues have been closed and none exist at this time, e final assessment of BCAP wtll be provided in the IE0G final report.

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2.0 INTRODUCTION

i This is the Fourth Interim Report which documents IE0G activities-for the period April through June 1985. This is the

< last interim report for the IEOG overview of the Braidwood Construction Assessment Program (BCAP). This report and the first three interim reports document IE0G activities from March 1984 through June 1985. A final report summarizing IE0G activities will be issued.

As stated in earlier reports, this report addresses the progress of the IE0G in overviewing BCAP during the reporting period and is not intended to reiterate the intent or scope of BCAP except as related to IE0G activities during the specified j three-month period.

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I 3.0 ACTIVITIES AND ACCOMPLISHMENTS 3.1 Staff Changes The IE0G staffing level is the same as that reported in the Third Interim Report except for the transfer of one inspector off the project and the shifting of engineering support during the

! The organization is depicted in Figure 3.1, latter part of June.

3.2 Overview Activities 3.2.1 General The overview activities of the IE0G have continued to keep pace with the activities of BCAP. No new activities were begun this reporting period. However, each existing overview activity was continued. The result has been a continuing, integrated overview of all BCAP activities.

i 3.2.2 Element Overviews Through personal contact and discussions with key p e o p 1 e ,

meetings, telephone conferences, reviews of documentation, surveillances, and overinspections, the IE0G has continued to overview each element of BCAP, BCAP administration and BCAP QA.

The IE0G continued its audit program of BCAP QA. These overview activities resulted in one audit concern, no audit action requests i

and three observations. Each of these was closed during this reporting period.

l Each of the overview activities is discussed in detail in the following sections. .

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PROJECT MANAGER J.L. H ANSEL OUALITY ASSURANCE MANAGER A E. COCOROS DEPUTY PROGRAM MANAGER R.E. HAM ADMINISTRATION C.M. THOMPSON *

- C.M. RICH ARDSON Y

08 SECRETARY D.L. TOGLIATTI MECHANICAL /PsPING ELECTRICAL HVAC CML/ STRUCTURAL AUDITS / INSPECT.

W.L CHASE N. A. PETRICK R.V. LANEY C.H. BROWN, JR. A.E. COCOROS

- R.W. ".3AIC

- W.A. PFElFER - T.A. KULAGA 3 - J.E. HOFF l C RECORDS MANAGEMENT I - C.J. SIMMONS CM. THOMPSOg P L - P.L. CLARK CSR - E.R. MOUSER R.E. HAM

]f RPSR METHODOLOGY W.L. CH ASE A.E. C OS FIGURE 3.1. IEOG ORGANIZATIONAL CHART

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3.3 Document Reviews There were no new programmatic documents issued by BCAP, BCAP QA or S &L (BCAP-related) in this reporting period. A number of

revisions and changes was issued which the IEOG has reviewed.

A number of new checklists / instructions was issued together with revisions of many others. The IE0G has reviawed each checklist and revision.

4 Because of the experience of the BCAP engineers in writing i BCAP documents and the maturity of the BCAP procedures, the

revisions to BCAP procedures and the new checklists which were issued were of a quality resulting in fewer IE0G comments. There was one mandatory commment and a few highly desirable comments t issued during this reporting period. The single mandatory comment dealt with instruction / checklist number CSR-R-E-EIN, Rev. 0 wherein it appeared that the instructions permitted the signature j of a Level I inspector to approve an inspection. Since this is unacceptable, the IE0'G issued a mandatory comment requiring the signature of a Level II or higher inspector. BCAP concurred and clarified their intent. The item is closed as are the highly i desirable comments.

I The documents reviewed by BCAP are listed in Table 3.1, and I

the checklists / instructions in Table 3.2.

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Table 3.1 Documents Reviewed

, Document No. Title Rev. No.

! BCAP-03 Records Management 3, Chg. 1 BCAP-04 BCAP Interface with Contractors and A/E 3 BCAP-06 Observation and Discrepancy / Concern Processing 8 BCAP-07 BCAP Reports 2. Chg. 1 i

BCAP-08 Qualification and Certification of Reinspection Personnel 2 j

l BCAP-21 CSR--Sample Selection 6 BCAP-22 CSR--Preparation of Instructions and Checklists 2, Chg. 1 BCAP-23 CSR--Preparation of Reinspection and l

Document Review Packages 2, Chg. 1 l BCAP-24 CSR--Performance of Reinspection and Document Review 3, Chg. 1 BCAP-25 CSR--Evaluation of Results 1 QASI-02 Corrective Action Requests 4 QASI-06 Document Reviews 5 QASI-08 Audits 4 QASI-09 Documentation / Records Control 3 QASI-15 Sample Selection 3,4 QASI-16 Performance of Reinspection and Document Review Overview 5,6 QASI-18 Evaluation of Reinspector Performance 0,1,2 i

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i Table 3.2 Checklists Reviewed Rev. No. l Document No. Title CSR-R-E-CPH Category 1 Cable Pan Hangers--Doc. Review 0 CSR-I-E-EIN Electrical Equipment Installation 1,2 CSR-R-E-EIN Electrical Equipment Installation--

Doc. Review 0,1 CSR-I-G-CEA Concrete Expansion Anchor Assemblies 1 CSR-R-G-CEA Concrete Expansion Anchor Assemblies--

Doc. Review 0 CSR-I-G-NFS Visual Inspection of ASME Welds (NF) 2 CSR-R-G-ASM ASME III Pipe and Pipe Support Welds--

! Doc. Review 1 CSR-R-G-NDI Review of NDE Documentation 1 CSR-R-G-ELE AWS D1.1 Welds (Electrical Work)--Doc. Review 1,2,3 l CSR-I-G-CTG Visual Inspection of Coatings 1 CSR-R-G-CTG Coatings--Doc. Review 0 CSR-R-H-01 HVAC Duct--Documentation Review 2 CSR-R-H-02 HVAC Equipment Installation-- Doc. Review 1 CSR-R-H-03 HVAC Hangers & Aux. Steel--Doc. Review 2 C S R -I -H -04 HVAC Housings and Plenums Fab. 1 CSR-R-H-04 HVAC Housings and Plenums Fab.--Doc. Review 1 CSR-I-H-05 Mechanical Equipment--Fidld Fab Tanks 1 CSR-R-H-05 Mechanical Equipment--Field Fab Tanks--

Doc. Review 0,1,2,3 CSR-I-H-06 Mechanical Equipment Installation 0 C S R -R -H -06 Mechanical Equipment Installation--

Doc. Review 0,1,2 C S R -R -H -0 7 Touch Up Galvanizing on HVAC Sheet Metal Duct Welds--Doc. Review 1 8

l Table 3.2 Checklists P.eviewed (continued)

Document No. Title Rev. No.

CSR-I-H-08 NSSS Equipment Installation 0 CSR-R-H-08 NSSS Equipment Installation--Doc. Review 0 i

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CSR-I-H-010 NSSS Support Verification 1 C S R -R -H -010 NSSS Support Verification--Doc. Review 0 CSR-R-M-1 Small Bore Piping Configuration--

Doc. Review 2 CSR-R-M-2 Large Bore Rigid Pipe Supports--

Doc. Review 1 C S R -R -M-3 Large Bore Non-Rigid Pipe Supports--

Doc. Review 1 CSR-R-M-6 .Small Bore Piping Supports--Doc. Review 1 CSR-R-M-9 Small Bore and Instr. Pipe / Tube Welds--

Doc. Review 0 i CSR-R-M-12 Large Bore Pipe Welds / Material--

Doc. Review 0 CSR-I-M-15 Instrument Pipe / Tube Supports 0,1 CSR-R-M-15 Instrument Pipe / Tube Supports--Doc.. Review 0 CSR-I-S-001 Concrete Placements 3,4

.CSR-R-S-001 Concrete Placements--Doc. Review 2,3 CSR-I-S-002 Structural Steel 2 CS R -R -S -002 Structural Steel--Doc. Review 1 CSR-I-S-004 . Masonry Walls 2,3 CSR-R-S-004 Masonry Walls--Doc. Review 0  !

CSR-I-S-005 Liners 0,1 CSR-R-S-005 Liners--Doc. Review 0,1,2 CSR-R-S-007 Post Tensioning--Doc. Review 1 9

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3.4 Ove view of CSR 3.4.1 Overinspections l In addition to the review of documents and checklists reported in Section 3.3 and in accordance with the protocol established between Commonwealth Edison and the Nuclear Regulatory Commission, the IE0G has continued its overview of the BCAP inspection activity. This has involved

, overinspection of verification packages af ter BCAP inspectors j have finished their inspection, surveillance of BCAP inspectors as they do their inspections, and reviewing l

{ documentation supporting the installed hardware.

) The list of verification packages overinspected, surveilled or reviewed is shown in Table 3.3. In this table the package numbers appear only once, but in some cases l inspectors from more than one discipline were required to'

complete the inspection package. For instance, in the electrical (E) packages, at times both the Electrical and

! Mechanical / Welding inspectors were required to do the l inspections.

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In this reporting period, the IEOG inspectors t

i overinspected 124 packages. From these overinspections three t

observations were written. These are discussed in detail in Section 3.8 and copies are included in Appendices 5.5.

1 The IE0G continued the work begun during the last period of reviewing the documentation supporting the hardware inspected by the IEOG inspectors. During this reporting period, IEOG inspectors reviewed 84 documentation review i packages. These are listed in Table 3.3. No discrepancies not reporten by the BCAP inspectors were found.

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Table 3.3 Verification Packages Overinspected, Surveilled or Reviewed by the IE0G OVERINSPECTIONS l CSR-I-E-CPH-041 CSR-I-E-EIN-111 C S R -I -E -E I N -10 3 i CSR-I-E-CPH-058 C S R -I -H -0 01 - 120 C S R -I -H -00 5 -0 0 8 f

CSR-I-M-002-040 CSR-I-H-001-107 CSR-I-M-004-060 C S R -I -E -C P H -0 5 3 CSR-I-M-006-088 CSR-I-M-009-063 CSR-I-E-CPH-054 CSR-I-E-CPH-112 CSR-I-M-012-049 CSR-I-M-002-084 CSR-I-H-004-012 CSR-I-S-001-014 CSR-I-S-002-044 C S R -I -E -C P H -113 CSR-I-M-009-055 CSR-I-S-002-032 C S R -I -E -C P H -12 5 CSR-I-M-012-120 CSR-1-H-003-037 CSR-I-E-CPH-126 CSR-I-H-002-017 C S R -I -H -00 3 -0 2 9 CSR-I-M-002-106 CSR-I-M-009-120 CSR-I-E-C0H-006 CSR-I-E-CPH-129 CSR-I-M-015-083 C S R -I -S -002-00 5 C S R -I -E -C P H - 13 0 CSR-I-M-015-092 C S R -I -S -0 0 2 -0 40 CSR-I-E-CPH-051 CSR-I-M-004-033 CSR-I-S-002-057 CSR-I-E-CPH-128 CSR-I-S-005-036 .

CSR-I-S-002-136 CSR-I-E-CPH-132 C S R -I -E -C B L - 10 5 C S R -I -E -C P H -019 CSR-I-M-003-057 CSR-1-M-009-094 C S R -I -E -C PH-0 26 C SR -I -E -C PH -04 8 CSR-I-S-001-047 C S R -I -E -C P H-03 9 CSR-I-E-CPH-163 CSR-I-S-001-107 C S R -I -H -00 7 -0 5 7 C S R -I -E -C P H - 16 4 CSR-I-H-008-016 CSR-I-S-002-103 CSR-I-M-003-048 C S R -I -E -E I N -131 C S R -I -E -C P H -04 9 CSR-I-M-003-062 CSR-I-E-EIN-139 C S R -I -E -C P H -0 5 0 CSR-I-M-005-096 CSR-I-S-005-020 CSR-I-H-003-013 C S R -I -E -C 0H -0 7 6 CSR-I-S-005-044 CSR-I-S-005-001 CSR-I-E-COH-118 C S R -I -E -C0H -00 7 CSR-I-E-CPH-115 CSR-I-E-C0H-123 CSR-I-E-C0H-107 C S R -I -E -C P H -131 CSR-I-E-CPH-118 C S R -I -E -CND -0 3 0 C S R -I -E -C P H -13 9 CSR-I-E-CPH-123 C S R -I -E -C ND -04 0 C S R -I -E -C P H - 14 9 CSR-I-M-003-053 CSR-I-H-008-103 CSR-I-M-003-008 CSR-I-M-005-021 CSR-I-E-CBL-013 C S R -I -E -C P H -101 CSR-I-S-004-028 C S R -I -E -C B L -0 2 0 C S R -I -E -C P H -10 3 CSR-I-M-001-061 C S R -I -E -C B P -012 C S R -I -M-012 -081 C S R -I -E -C B L -10 2 C S R -I -E -CB P -0 5 0 CSR-I-M-012-128 C S R -I -E -C B L - 10 9 CSR-I-M-002-114 C S R -I -E -C P H -10 6 C S R -I -E -C 0 H -121 C S R -I -E -C P H -0 4 3 CSR-I-E-CPH-108 CSR-I-E-CPH-159 C S R -I -E -C P H -0 5 5 CSR-I-M-012-126 CSR-I-E-CPH-160 CSR-I-H-003-122 CSR-I-S-002-132 CSR-I-M-006-075 C S R -I -E -E I N -0 4 9 CSR-I-M-002-022 CSR-I-M-009-003 ' C S R -I -E -E I N-0 5 9 CSR-I-M-006-035 CSR-I-M-009-054 CSR-I-M-006-039 CSR-I-M-012-095 CSR-I-M-012-078 CSR-I-S-004-054 CSR-I-M-002-062 CSR-I-E-EIN-053 11

Table 3.3 (continued)

REVIEW SURVEILLANCE C S R -R -S -006 -012 C SR -R -M-00 3 -0 5 7 C S R -I -E -C B L -116 C S R -R -S -00 6 -017 CSR -R -M-0 0 3 -0 6 2 CSR-I-E-CBL-117 C SR -R -E -C ND-0 4 4 CSR-R-M-004-026 CSR-I-E-CBL-133 C S R -R -E -C N D -0 5 3 CSR-R-M-004-033 -

CSR-I-E-EIN-001 C SR -R -E -CND -0 6 2 C S R -R -M -0 0 4 -0 3 8 CSR-I-E-EIN-005 C S R -R -E -C N D -0 6 3 CSR-R-M-004-060 CSR-I-E-EIN-006 C S R -R -E -C N D -0 6 4 C S R -R -E -C B P -011 C S R -I -E -E I N -112 CSR-R-E-CND-077 CSR-R-E-CBP-060 CSR-I-E-CPH-166 C S R -R -E -C B L - 112 CSR-R-E-CBP-116 CSR-I-S-005-001 C S R -R -M -0 01 -018 CSR-R-M-004-026 CSR-I-S-005-034 C S R -R -M -001 -0 2 4 CSR-R-M-004-033 CSR-I-S-005-033 C S R -R -M -001 -0 2 8 CSR-R-M-004-038 CSR-1-E-CPH-111 C S R -R -M-001 -0 7 2 C S R -R -M-00 4 -0 6 0 CSR-I-S-005-011 C S R -R -E -C B L -017 CSR-R-M-005-021 CSR-I-S-005-014 C S R -R -E -C B L - 10 5 CSR-R-M-005-048 C S R -I -E -E I N -13 4 C S R -R -E -C e c - 10 9 CSR-R-M-005-094 CSR-I-E-CPH-127 C S R -R -M -00 2 -0 2 2 CSR-R-M-006-034 CSR-R-M-002-049 CSR-R-M-006-056 C SR -R -M-002 -0 7 8 C SR -R -M-0 06 -0 7 5 C S R -R -M -002 -084 CSR-R-M-006-088 C S R -R -S -0 01 -04 7 C S R -R -E -C B P - 119 C S R -R -S -001 - 10 7 C S R -R -E -C B P - 12 6 C S R -R -E -E I N -0 5 3 CSR-R-E-CBP-130 C S R -R -E -C 0H-0 06 CSR-R-M-005-021 C S R -R -E -C 0H --31 C SR -R -M-00 5 -04 8 C S R -R -E -C 0H -04 7 CSR-R-M-005-094 C S R -R -E -C0H-0 7 6 CSR-R-M-006-034 C S R -R -E -C 0 H -118 C SR -R -M -00 6 -0 5 6 LEGEND C S R -R -E -C0 H -121 CSR-R-M-006-075 I---Reinspection C S R -R -E -C 0 H -12 3 CSR-R-M-015-083 R---Documentation C S R -R -E -C B L -112 C S R -R -M -015 -0 9 2 Review CSR-R-M-001-018 CSR-R-H-002-005 E---Electrical

C S R -R -M -001 -0 2 9 CSR-R-H-002-007 H---HVAC C S R -R -M -0 01 -0 4 9 CSR-R-H-002-017 M---Mechanical C S R -R -M -001 -0 61 CSR-R-H-002-026 S---Structural C S R -R -E -E I N -10 3 CSR-R-H-002-031 EIN-Electrical C S R -R -E -E I N -131 CSR-R-H-001-004 Equipment C SR -R -E -E I N-13 9 CSR-R-H-001-019 CBL-Cables C S R -R -M -003 -00 5 CSR-R-H-001-042 CBP-Cable Pans C S R -R -M -00 3 -008 CSR-R-H-001-107 CND-Conduit C S R -R -M-003 -0 5 3 CSR-R-S-006-005 C0H-Conduit Hangers

. CPH-Cable Pan Hangers 12 l

3.4.2 Rev1ew of S & L Evaluation of CSR Observations Review of S '& L evaluations of BCAP observations f continued during this reporting period. These reviews l continue to follow the guidelines reported in the Third

! Interim Report, i.e.:

! o Appropriateness o Reasonableness o Completeness o Applicability l

Reviewer questions pertaining to the S & L Evaluation were further pursued through discussion with S & L liaison

! engineers and by a review'of calculation packages in the l depth necessary to resolve the question.

Results through this reporting period show that S & L 1

evaluations justify design adequacy for all observations reviewed to date. A significant number of observations have been assessed by the IE0G through this reporting period.

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3.5 Overview of RPSR

During this reporting period, RPSR engineers reviewed l procedures written by NISC0; G. K. Newberg Construction l Company; Pittsburgh Testing Laboratory; Phillips, Getchow Company; Pullman Sheet Metal Works, Inc.; and Chicago Bridge and Iron Works. This brings to nine the number of companies whose procedures have been reviewed and completes the review I

! of procedures. In total, RPSR engineers have reviewed 592 procedures against the RPSR checklists which listed the f- requirements. These reviews have resulted in 224 l

observations. The packages containing the completed checklists and observations have been delivered to the IEOG i for review.

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The IEOG review of the completed checklists has indicated that RPSR had done an adequate job in reviewing the procedures of the nine contractors. These included the requirements of the specifications and the requirements

! delineated in the FSAR, in Regulatory Guides, and in various national standards in their review. These reviews of the RPSR packages by the IE03 have resulted in no comments.

L RPSR has written a number of observations. RPSR engineers are reviewing these for validity at this time and the IE0G will overview this process.

l 3.6 Overview of RSCAP The IE0G has continued to overview RSCAP by review of j checklist closeout, by discussions, and by acting as

! observers during a BCAP QA audit.

During this reporting period, RSCAP has completed its f

review of eight of the nine significant corrective action programs. Draft reports on these have been written and are being reviewed within BCAP management.

The ninth significant corrective action program, Quality Control Inspector Reinspection Program, has been started. -

The IE0G will overview the RSCAP activity on this.

RSCAP is still doing an acceptable job of assessing the corrective action programs. The final IE0G assessment of RSCAP will be available after the evaluation 'of RSCAP final reports.

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3.7 Audits As reported in the Third Interim Report, in order to

! provide an effective assessment of BCAP operations with a

! minimum disruption of activities, the IE0G elected to act as observers during BCAP QA audits of the BCAP program and to i

conduct audits only of the BCAP QA operation. Since this has proved to be an efficient and effective means for the IEOG to

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! evaluate the BCAP program, the IE0G has continued this audit practice.

3.7.1 Overview of BCAP QA-Audits i IE0G personnel were observers during three audits l conducted by BCAP QA. These audits are listed in Table 3.4.

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! During these audits, IE0G personnel observed the BCAP QA .

j auditor's conduct insofar as thoroughness, effectiveness and action. It was concluded that BCAP QA was performing I

meaningful audits.

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Table 3.4 IE0G Overview of BCAP QA Audits Audit No. Date Performed item Audited BQ AA IV-015 5/02 - 10/85 BCAP-01 Program Indoctrination for Employees BCAP-20 CSR--Establish Populations BCAP-21 CSR--Sample Selection BCAP-22 CSR--Preparation of Instructions and Checklists BCAP-23 CSR--Preparation of Reinspection and Doc.

Review Packages BCAP-24 CSR--Performance of Reinspection & Document Reviews l l

BCAP-25 C3R--Evaluation of Results BQ AA IV-016 5/24-31/85 BCAP-02 Organization and Responsibility BCAP-03 Records Management BCAP-04 BCAP Interface with Contractors and Architect / Engineer BCAP-07 BCAP Reports BCAP-08 Qualification and Certification of Reinspection Personnel BCAP-41 RPSR--Identification of Specification and Contractor Procedures 16

Table 3.4 IE0G Overview of BCAP QA Audits (continued)

Audit No. Date Performed Item Audited BCAP-42 RPSR--Preparation of Checklists BCAP-43 RPSR--Review of Contractor Procedures BCAP-60 RSCAP--Review Methods BQ AA IV-017 6/18 - 7/01/85 PI BB 75 Engineering Evaluations of BCAP Discrepancies /

Concerns BCAP-06 Observation and Discrepancy / Concern Processing

)

I 17

- . - _ _ - - -. - -. . __ - _ _. . . = _

i i

3.7.2 IE0G Conducted Audits

! In keeping with the policy to audit the implementation l Of the BCAP QA Program, the IEOG conducted one audit during l this period (ERC 85-105 during 5/29-31/85). The scope of the audit was to determine that BCAP QA was satisfactorily implementing BCAP QA Special Instruction QASI-18, Rev.1,

" Evaluation of Reinspection Performance," and to perform a follow up on IE0G Audit ERC 85-104 for the implementation of i

QASI-15 Rev. 4, " Sample Selection," and QASI-16 Rev. 6, j " Performance of Reinspection and Documentation Review f Overview."

j The audit was conducted by an audit team led by a j certified Lead Auditor meeting the requirements of ANSI /ASME l N45.2.23, " Qualification of Quality Assurance Program Audit l Personnel for Nuclear Power Plants." The audit team members

, met the qualifications specified for auditors.

An audit plan and checklist were developed by the Lead i

Auditor for this audit and approved by the ERC Quality l Assurance Manager.

During tne course of the audit there were no findings;

(

! however, one area of concern was identified which was cleared ,

while the audit was in progress. This concern dealt with the use of a form different from that specified in QASI-18.

l During the audit, QASI-18 was revised to incl.ude the form

! being used. The revised procedure was approved prior to the, l audit exit conference.

i l

l

)

4 j

18

5 3.8 Reports of Deviation Although the IE0G scrutiny remained the same as earlier, corrective actions implemented by BCAP personnel  !

l significantly reduced the number of discrepancies discovered, i

i 3.8.1 Notices of Concern (NOC) 4 During this reporting period there were no N0C's issued.

,I j 3.8.2 IEOG Observations j A total of three IE0G observations were issued during j this reporting period. In contrast to the last reporting

$ period, this is a significant reduction. None of these -

! observations was determined to be design significant. Copies of these observations are contained in Appendix 5.5.

] 3.8.2.1 Observation BCAP-0BS-016 j This observat' ion identified discrepant conditions on l five different AWS fillet welds on cable pan hangers.

The discrepant conditions were minor and the BCAP response included the issuance of formal BCAP observations

) and additional training. The BCAP response was acceptable

and the observation has been closed, i

i j 3.8.2.2 Observation BCAP-0BS-017 l This observation identified discrepant conditions on leg sizes for AWS fillet welds.

The BCAP response included issuance of a formal BCAP

observation, inspector counseling and a review of the

inspector's past discrepancy record. The initial concern of the IEOG regarding the potential need for reinspection of the 1 particular inspector's previous work was alleviated in the 1

19 _

BCAP response. This response pointed out that of 523 welds inspected by the inspector, only 15 were represented by IECG observations. None of these discrepancies was considered design significant. Additionally, a BCAP Level III weld inspector reinspected 183 different welds inspected by the inspector in question. None was found in disagreement; therefore, the BCAP response was considered to be acceptable and the observation has been closed.

3.8.2.3 Observation BCAP-0BS-018 The discrepant condition noted for this observation was the absence of stiffener steel angles on an electrical junction box which was not noted in<the BCAP observation.

The BCAP response included a review of the entire population and issuance of BCAP formal observations for that junction box and two (2) additional ones uncovered in the reinspection. BCAP also counseled the inspectors regarding care in reading the drawings and in follow up in identifying these kinds of missing parts. The BCAP response was acceptable and the observation has been closed.

3.9 Issues 3.9.1 Status of Issues from Previous Interim Reports Du ring this reporting period, BCAP personnel made a concerted effort to close all outstanding issues. That effort was successful and, as of this report date, all issues opened previously are closed.

3.9.2 Issues Raised This Reporting Period The only issues raised this reporting period are the observations listed in Section 3.8 above. All are closed.

20

3.9.3 Open Issues at the End of the Period None.

9 4

21

4.0 IEOG ASSESSMENT 0F BCAP TO DATE As stated in previous reports, the IE0G believes that the BCAP, as performed, will achieve the program objectives.

At this time, most of the evaluations have been completed and the preparation of final reports has been initiated. All results to date appear to support the accomplishment of the

! progran objectives defined in June 1984 CSR inspections have been completed and the results are i being readied for compilation and summarization. Based on t BCAP QA and IE0G overinspections, approximately twenty-five percent of BCAP inspections were independently checked with acceptable agreement among the results.

In the IE0G's judgement, RPSR is performing an adequate review of contrac' tor construction procedures. Refer to paragraph 3.5 for summary discussion and status.

i r

The RSCAP is in the final stages of completion with eight of the nine significant corrective action programs having been evaluated. The IE0G assessment of RSCAP's performance is that RSCAP has provided an adequate review of '

l eight of the nine significant corrective action programs ,

assigned to be reviewed. The ninth, Quality Control i Inspector Reinspection Program, has just begun.

Based on IEOG surveillances and audits to date, the IE0G judges that BCAP QA has continued to perform a good overview of BCAP.

The final assessment of BCAP will be provided in - the IE0G Final Report.

22 -. -

5.0 APPENDICES l

5.1 RESUMES l

l 1

1 FRANKLIN R. H00GES Thirty years of continuous industrial experience with over ten years in nuclear power plant design and construction. Experience levels range from

' " hands on" maintenance to progressive management positions in the areas of quality control and quality assurance in aerospace and nuclear construc-tion.

EXPERIENCE 5/85 - Present EVALUATION RESEARCH CORPORATION (ERC), Oak Ridge, TN, Quality Assurance Manager Manage and direct topical quality assurance programs i established for ERC professional services contracts with government agencies and commercial clients.

. 5/84 - 5/85 CONSULTANT - SELF EMPLOYED, Oak Ridg.e, TN i Provided quality assurance engineering service's to the Department of Energy (Project Management Corporation) j durin'g the termination of the Clinch River Project.

5/80 - 5/84 PROJECT MANAGEMENT CORPORATION (PMC), Oak Ridge, TN, Quality Assurance Program Manager, Constructor Managed and directed day-to-day quality assurance

~.

activities of Stone & Webster Engineering Company (Constructor) for PMC during the design, procurement, and construction of the Clinch River Breeder Reactor Pl ant.

3/74 - 5/80 PUBLIC SERVICE COMPANY OF INDI ANA (PSI), Plainfield, IN, Quality Assurance Manager Managed and directed corporate quality assurance program ,

I during the design, procurement, and construction of the Marble Hill Plant.

11/73 - 3/74 RALPH M. PARSONS CONSTRUCTION COMPANY (RMP), Monroe, MI, Mechanical Quality Control Engineer Supervised and directed mechanical quality control inspectors during the construction of the Enrico Fermi 2 Plant.

l 25

Franklin R. H:dgss - 2 7/73 - 11/73 DANIEL CONSTRUCTION COMPANY (DOC), Greenville, SC, Quality Assurance Engineer l

Prepared and coordinated quality assurance and quality control procedures for 10 CFR 50, Appendix B and ASME Section III, Division 1 application at the Allied-Gulf Nuclear Fuel Reprocessing Facility and the Joseph M.

Farley P1 ant.

2/71 - 7/73 BENDIX LAUNCH SUPPORT DIVISION (BLSD), Kennedy Space l Center, FL, Quality Assurance Engineering Specialist Directed and coordinated for NASA, Davis-Bacon contracts for modifications to Apollo and Skylab launch facilities. _

5/56 - 2/71 Quality Assurance Foreman Supervised and directed quality assurance technicians during the operation and _ maintenance of Apollo Program launch support equipm_ent.

5/55 - 5/66 BOWATER SOUTHERN PAPER CORPORATION (BSPC), Calhoun, TN, _

Journeyman Millwright Performed maintenance and installation of fossil fired boilers, turbines, and electrical generators.

EDUCATION I

1976 Purdue University, Civil Engineering Major 1971 -

A.S., Brevard Community College, Quality Control and Reliability 1961 Millwright Apprenticeship, Bowater Southern Paper Corporation Various company and industry training programs including Purdue University Management Program I-IV and Westing-house PWR Simulater and Plant Operation Program CERTIFICATIONS Quality Control Engineer, ASQC E-2391 l Quality Assurance Lead Auditor, ANSI /PMC Quality Assurance Auditor, ANSI /PMC Quality Assurance Level III Engineer, ANSI /PMC Soils Inspector Level II, ANSI /TVA Concrete Inspector Level II, ANSI /TVA l REGISTRATIONS Professional Quality Engineer, California QA-1360 PATENTS Medical Testing and Data Recording Apparatus, No. 3,786,510, United States of America 25 l

Laticia P. Adkins Fifteen years experience in Quality Control inspection and Quality Assurance audit activities. The last six years experience has been related to nuclear power plant construction. l May 1985 - Present Evaluation Research Corp., Oak Ridge, TN.

Documentation Specialist - Responsibilities include performing audits and coordinating quality assurance /

quality control activities between ERC and Common-wealth Edison - Braidwood Construction Assessment Program.

July 1980 - May 1985 Project Management Corp., Oak Ridge, TN.

Quality Assurance Specialist - Responsibilities included performing surveillance and audits to assess .

the adequacy of supplier activities and documentation

. to determine conformance to contractual and Government requirements. Also monitored supplier shipping,

_ storage, and maintenance program activities.

Quality Verification Administrator - Responsibilities included performing surveillance and audits and I coordinating Quality Assurance Program activities for l Clinch River Breeder Reactor Plant contractors. l Administered the Quality Assurance Program, edited and issued audit reports, evaluated Corrective Actions for acceptable completion, and performed audit closure verification. ,

Mar. 1970 - Dec. 1979 Monsanto Research Corp., Mound Laboratory, Miamisburg, Ohio NDE Radiographic Technician (QC Inspector) - Performed radiographic tests and film analysis on nuclear weapons components. Developed test procedures and assisted in writing test methods and procedures manuals.

, Performed helium leak tests and neutron radiography at Battelle Institute and Argonne National Lab.

Technical Editing Clerk - Responsibilities included editing, layout and designing monthly, annual, and technical publications.

27

h Laticia P. Adkins - 2 Certifications: Quality Assurance Lead Auditor, ANSI N.45.2.23 Quality Assurance Auditor, ANSI N45.2.23 X-Radiography - Level II, ASNT-TC-1A Neutron Radiography - Level II, ASNT-TC-1A Liquid Penetrant Testing - Level II. ASNT-TC-1A Helium Leak Testing - Level II, ASNT-TC-1A Eddy Current Testing - Level II, ASNT-TC-1A Magnetic Partical Testing - Level II, ASNT-TC-1A Ultrasonic Testing - Level II, ASNT-TC-1A Special Qualifications: Active "Q" Clearance Education: Roane State Community College, Harriman, TN.

University of Tennessee, Knoxville, TN.

Oak Ridge Associated University, Oak Ridge TN.

Sinclair Community College, Dayton, Ohio

~

Miami University, Middletown, Ohio (Select courses regarding Nondestructive Evaluation, Quality Control Fundamentals, and Statistics)

O e

I l

1 28

Ralch Woodrum Craig Twenty-five years experience in electro-mechanical engineering field with the last eighteen being in the nuclear power plant field. Experience encompasses project management, project engineering, engineering management, construction liaisen for installation and erection of reactor coolant and auxiliary system components as well as electrical system components.

i EMPLOYMENT:

1985 - Present Evaluation Research Corporation, Roanoke, VA.

Senior Consultant. Responsibility encompasses expert overview of Quality Assurance findings for reinspection of Nuclear Power Construction Overview.

1967 - 1985 Babcock and Wilcox Co., Inc., Nuclear Power Division, Lynchburg, VA.

1984/1985 - At Termination: Project Engineer Bellefonte 1 & 2, NSS Project Services Responsible for project management of design changes for field modifications to NSS's. Reactor internals and various Instrumentation and Control System changes.

These changes in scope required project management of engineering, procurement and site support of installation.

This position required coordination of procurement, engineering and construction.

, 1980/1984 - Associate Project Manager ,

Midland Units 1 & 2, NSS Project Services Responsible for project management of assigned scope for the Consumers Poder Units 1 & 2. The primary scope included NSS loop and associated engineering and procurement required to se, port the site during field modifications. During this time r".4 '-.sumers Power made major field modifications to the

.35 staan. generators and reactor internals. Early in this time period, responsibilities included the establishment and mainten-ance of project schedule system to support engineering and construction activities.

1979/1980 - Product Manager Responsible for project management activities on NSS hardware upgrades and modification. Numerous upgrades were initiated in this time period for TMI-II related changes.

29

i Ralch W. Craio - 2 1976/1979 - Previous: Unit Manaaer, NSS Project Schedules Responsible for NSS project schedule personnel engaged in preparation and coordination of engineering and production schedules of B & W's NSS Systems. This activity required the coordination of NSS component manufacturing, vendor deliveries and transportation schedules for NSS hardware.

1972/1979 - Previous: Technical Manager,-International Engineering Support I Responsible for technical support and export of B & W's Nuclear Technology to a German subsidiary company engaged in the design and supply of NSS in Germany. Three associate technical managers reported to me in this capacity.

1967/1972 - Previous: Group Supervisor, Electrical Equipment Responsible for engineering design of electrical equipment in B & W's NSS scope of supply. This scope varied from Reactor Coolant Motors to Control Rod Drive Control System.

Interface of the NSS electrical system with the Architect Engineer and liaison with utility was required to satisfy numerous control requirements.

1967 Johnson Carper Furniture Company Plant Encineer. Responsible for maintenance and construction of plant expansion for Upholstered Division Plant. Scope of duties covered all phases of plant equipment and operation to support production of upholstered furniture.

1959 - 1967 Thompson Ramo Wooldridge (TRW), Rocky Mountain, VA.

Project Manager / Engineer.

Responsible for project management functions in the supply of Ground Support Equipment to the Department of Defense and other prime defense department contractors. Both engineering designers and manufacturing personnel supported the fabrication of the GSE. Also during this time period, functioned as Environmental Test Engineer for missile and space applications to NASA and 00D. Primarily resposible for dynamic viabration and shock test labs.

30

Raloh W. Craio - 3 PROFESSIONAL AFFILIATIONS:

Nona EDUCATION:

1955 - 1959 Roanoke College Pre Engineering Virginia Polytechnic Institute BSME 4

I

\

1 1

l 1

1 1

31

I 5.2 TRAINING RECORDS

t s m o s i n er, u n A6 tn t e x t e r, A s a u ri QUAL 11Y ASSURANCE RE CORD Or AS$1Gbf D RE ADING ASSIGNED 10: Laticia'P. Adkins 5.5. NO: 282-44-6666 I

EMP. NO:

3 Doc.

c. No. Rev. Title Date Completed 0 -

Indoc. BCAP M g/pf

/

12/13/84 1 BCAP Policy-Errata Letter

~

2 BCAP Overview Plan G BCAP 01 3 Program Indoc. for Employees f, ff BCAP 02 3 Organization & Responsibility

/

Mr .

~

BCAP 03 3 Change 1 Records Management --

_ g

/ /

BCAP 04 3 BCAP Interface w/ Contractors & Arch./Eng.

/

/

BCAP 06 8 Obs. & Discrep./ Concern Processing hg BCAP 07 2 Change 1 BCAP Reports -

BCAP 08 2 Qualifications & Certs. of Reinsp. Personnel Site QA Overview Group Plan -

1 f3 /3

/

2 ERC QA Plan fdg.

Signature acknowledges that I have read the documents and have been provided an opportunity to have questions on each of the above documents anst7ered ' to assure my understanding.

Signature I)/h) /Il7ab Date n#,Od,/9 M p

33

ts,,taiser, ht g r.in t h e o. a i l e r.

QUALITY ASSURANCE RE CORD OF ASS I Cd[ D R E ADI NG ASSIGHED 10: Laticia P. Adkins 5.5. NO: 282-44-6666 EMP. NO:

Doc.

No. Rev. Title Date Completed 0AP 1.1 1 Personnel Qualifications 5/2c[Ff QAP 1.2 0 Indoc. & Training of Personnel g20[K QAP 2.1 1 Caily Log -

g/2 Ef 0AP 4.1 1 Procurement Doc. Control g/go[7f 5/24ff Acceptable Source List I QAP 4.2 0 -

QAP 5.1 0 Preparation, Review & Approval of QA P g g _

- i QAP 6.1 1 Distribution & Control of QA Docs. /pf 0AP 10.1 2 Quality Review & Surveillance g/g/gg QAP 10.2 2 Qualifications of Inspection Personnel [g Selection of Samples for ERC QAP 10.4 3 Overinspection/ Doc. Review g i QAP 10.5 0 Trend Analysis / fg QAP 10.6 1 ERC' Review of S&L Eval. of BCAP Obs. /,_

i l

l Signature acknowledges that I have read the documents and have been provided an opportunity to have questions on each of the above documents answered to assure my understanding.

Signature .d$ e ) uNo Date  % 2'1,1975 .

p 34

s i, s e i s s a s t > t s t n utsesr.~iath QUAllTY ASSURANCE l

l RIC0kD Of A551Gt.ED READING ASSIGNED 10: Laticia'P. Adkins 5.5. NO: 282-44-6666 EMP. NO:

Doc.

No. Rev. T it le Date Completed 0AP 15.1 1 Doc.& Disposition of Obs. & Discrep. 6- gg QAP 16.1 0 Corrective Action ofgfg-QAP 17.1 1 QA Records Program - bhhg-QAP 18.1 2 QA Audit Program ,7 ff QAP 18.2 1 -

Qualifications of Audit Personnel

~

ANSX N45.2.6 1978 Qualifications of Inspec. Exams & Test _Persenn_,

Requirements for Collection, Storage, &

ANSX N45.2.9 1974 Maintenance of QA Records

[f

//

ANSI N45.2.10 1973 QA Terms & Definitions

j Requirements for Audit of QA Programs ANSI N45.2.12 1977 for Nuclear Power Plants- 6)p/[gc ANSI N45.2.23 Qualif. of QA Program Audit Personnel g'/gy gg 12/20/84 CECO Letter to NRC-Protocol g g pg-0 DP &P 101 '& 102 gg pf Signature acknowledges that I have read the documents and have been provided an opportunity to have questions on each of the above documents answered to assure my understanding.

Signature 9 hin ) -

M 3 Date Mao 3c-M.,/4[6 o

35

t.. .. . , m :.,. .- ,,- , - ..,

I Q U Al. l T Y ASSURANCE REC 0kD Cf A551CdfD READING ASS 1GriE D T 0 : Ralch W.'Craia 5.5. NO: 223-36-0953 EMP. NO: _ _ _ _ , _ _ .

Doc.

No. Rev. Title Date Completed 12/13/84 1- BCAP Policy Document G// (( <> w_h 2 BCAP Overview Plan /<//f

-(

t M AM.s 3 BCAP CSR Plan 4// E

'/

Q J 1 BCAP RPSR Plan 6//' f5 Sea  ;)

/ v 3 BCAP RSCAP Plan 6//g/,(( -

f 4) f u s t BCAP 06 8 ' Observation & Discreo./ Concern Pr essina / " '- -

BCAP 20 2 CSREstablishPoculations$!2/ __

F /

/ v BCAP 21 6 CSR Samole Selection 4 (/[$ et/M w(

BCAP 22 2 Change 1 CSR-Prep. of Instructions & C 3

BCAP 23 2 Change 1 CSR-Preo,of Reinspec. & Doc. Review Pko bhVb _fj)\A grg4 ' '

BCAP 24 3 Change 1 CSR-Performance of Reinsoec. & Doc R BCAP 25 1 CSR-Evaluation of Results

. ,/, - ,

M -

9 Signature acknowledges that I have read the documents and have been  !

provided an opportunity to have questions on each of the above documents answered to assure my understanding.

Signature 1 Date d, 2,.

36

t .-. . . .- s QUAll1Y ASSURANCE RECOLD OF A 5 51 G'.E D R E A D I N G

, A551GriED TO: Ralph W.'Craig 5.5. NO: 223-36-0953 l

EMP. NO: _ _ _ _ _ ,

Doc.

l No. Rev. litle Date g pley d BCAP 41 2- 48f/drC&43Qe RPSR-ID of Saecifications & Contractor hoced BCAP 42- 4 RPSR-Prep. of Checklists t

M d'#f3 BCAP 43 2 RPSR-Review of Contractor roc _ur 2 Q BCAP 60 2 Review Methods e2I/f[

~

2 ERC QA Plan QAP 2.1 1 . Daily Loo d T 412 M -

QAP 4.1 1 Procurement Doc. Control 4/f >4 QAP 4.2 0 Acceptable Source List g[ .

(

QAP 10.1 2 Quality Review & Surveillance ' -

I l

ysrC%4 -

QAP 10.4 3 SelectionofSamolesforERCOverinsoec[ ion / .. Review l

QAP 10.6 1 ERC Review of S&L Evaluations of BC P J servpt o S QAP 15.1 1 Document & Discosition of Obs. & Discre[ancies U Signature acknowledges that I have read the documents and have been provided an opportunity to have questions on each of the above documents anstered to assure my understanding.

~

Signature -

M, Date h[28/[3 9

37

t- . ~ . . . :. e t .~ . -

- u- .- ..

QUAllTY ASSURANCE REC 0kD OF AsslG IED READING 1

ASSIGNED TO: Ralch W. Craig 5.5. NO 223-3E-0953 EMP. NO: _ _ _ _ _ _ , _ _ ,

Doc.

No. Rev. Title Date Completed QAP 16.1 0- Corrective Action f[ ,, ,y A__

12/20/84 CECO Letter to NRC g[Q .

0 DP&P 101 k.2[ , , , y e '

0 DP&P 102 (# $ m f p .;

Signature acknowledges that I have read the documents and have been provided an opportunity to have questions on each of the above documents ansaered to assure my understanding.

Signature - 14 hoks Date d.

p 38

sus M

uma . MEMO May 21, 1985 T0: ERC Files FROM: J. L. Hansel i

SUBJECT:

Indoctrination of ERC Personnel per QAP-1.2 for BCAP IEOG An indoctrination session was conducted by Mr. W. L. Chase for L. P. Adkins at the Evaluation Research Corporation office on the Braidwood Site on May 21, 1985. The session ran approximately 60 minutes, and the following items were covered:

o Organization / Interf aces _

ERC-IE0G _

BCAP '

CECO .

. o Function BCAP IE0G o Procedures

, IEOG l BCAP & BCAP QA Projec.t i

I o Specific Responsibilities

! A l J. L. Hansel Project Manager JLH:REH/dit 39

]

]

]

1

- MEMO June 18, 1985 '

[

l TO: ERC Files FROM: R. E. Ham

SUBJECT:

Indoctrination of ERC Personnel per QAP 1.2 for BCAP-IE0G An indoctrination session was conducted by Mr. W. L. Chase for i Mr. R. W. Craig at the ERC office on.the Braidwood Site on June 17, 1985. The session ran approximately 60 minutes and the following items were covered:

o BCAP plan dccuments and their levels. l o Status of Program.

o Reviewed- BCAP definition and described the three elements.

o Reviewed his responsibilities in support of ERC.

i REH:LPA/dlt W

i f

40

l 5.3 QA/QC QUALIFICATION / CERTIFICATION RECORDS l

l .

I

I June 18, 1985 l

T0: ERC Files

SUBJECT:

Qualification of ERC Personnel / Employees performing work for the Braidwood Construction Assessment Program (BCAP)

I have reviewed the education records, professional work experiences and personal qualifications which I believe are required for R. W.

Craig to perform as a member of the ERC BCAP Independent Expert Overview Group, and find him fully qualified to so perform.

John L. Hansel Project Manager b ht

)

d d;g JLH:REH:LPA/dlt f

l l l

6 42

M

. MEMO l

May 21, 1985 T0: ERC Files

SUBJECT:

Qualification of ERC Personnel / Employees performing work for the Braidwood Construction Assessment Program (BCAP) i I have reviewed the education records, professional work experiences and personal qualifications which I believe are required for L. P.

Adkins to perform as a member of the ERC BCAP Independent Expert _

Overview Group, and find her fully qualified to so perform.

JC% 7 _

John L. Hansel Project Manager

_ JLH:REH:WLC/dlt .

G 43

3

' . MEMO l

May 21, 1985 QA-150 T0: ERC Files

SUBJECT:

Qualification of Auditors I have reviewed the education records, professional qualifications and work experience of Ms. L.P. Adkins and find her fully qualified as an Auditor for an ERC Audit- Team to perform audits in accordance with ANSI /ASME N45.2.12 and ERC Procedure QAP-18.1, " Quality Assurance Audit Program".

Cocoros n.t.

Quality Assurance Manager -

AEC:CMT/cmr l

l l

l l

l l

44

..-.,g O

5.4 IE0G AUDIT REPORTS

f rE i. .

< . FIELD OPERATIONS l

WMATION soo O.= R,oge turnoiwe suae soi WECEAWCM Oak Ridge. Tennessee 3783o COWPOWATION (615) 482-7973 June 13, 1985 BCAP-264 Commonwealth Edison Company Braidwood Station R.R. #1, Box 81 Braceville, IL. 60407 ATTENTION: Mr. N. P. Smith

SUBJECT:

ERC Audit No. ERC 85-105 May 29-31, 1985 Gentlemen:

Enclosed is the report'of the subject audit. There were no findings, however, one area of concern was identified which was resolved during the audit. The details are provided in the attached report. No response to the Audit Report is required.

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

Very truly yours, l

. . ros Quality Assurance Manager AEC/WLC/dit attach.

cc: T. Maiman N. Kaushal IEOGTeam[

(2) Files R. N. Gardner J. G. Keppler 46

i EVALUATION RESEARCH CORPORATION 00ALITY ASSURANCE AUDIT REPORT Audit No: ERC 85-105 Dates: 5/29-31/85 4

I. AUDIT SCOPE To evaluate BCAP QA Reinspection Performance and to verify corrective action on Audit ERC 85-104.

, 11. AUDIT TEAM W. L. Chase - Team Leader T. A. Kulaga - Auditor XIX. PERSONNEL CONTACTED N. P. Smith 1 R. C. Cannon 1,2,3 D. L. Smith 1, 2 J. A. Zych 1,2,3 W. J. Marcis 3 W. M. Sides 3 NOTE: 1 - Attended at the Pre-Audit Conference.

2 - Contacted during audit.

3 - Attended at the Post-Audit Conference.

IV.

SUMMARY

OF RESULT _S_

The completion of this audit resulted in no Audit Action

. Requests being issued. However, one item of concern was identified which was cleared while the audit was in progress. This concern dealt with the use of a form different from that specified in QASI-18. The form in use evaluated the BCAP QA inspectors by population. The form in 0ASI-18 evaluated the inspector across all populations. During the audit, QASI-18 was revised to include the form in use.

The revised document was approved prior to the audit exit conference.

The 'following is a summary of the criteria audited:

A. QASI 18, Rev. 1, " Evaluation of Reinspection Performance" This audit' verified that the Overview and Overinspection (0/0) Supervisor evaluates each BCAP Task Force Reinspector at least once each month. It was also verified that having performed the evaluation the 0/0 Supervisor provides these evaluations to the General Supervisor QA at a fixed time each month. It was ascertained that each Reinspector is evaluated for every population the Reinspector reinspected. This included the data required by the table designated in QASI 18. Specific sections of QASI-18 audited were 4.2.2, 5.2, 5.2.1, 5.2.9 and 5.2.11.

t OS

D 9

B. QASI-15, Rev. 4, " Sample Selection" This audit was conducted to verify the corrective action related to Audit ERC 85-104 All corrective actions were found to be satisfactory.

C. QASI-16, Rev. 6, " Performance of Reinspection and Docu-l mentation Review Overview" i

( This audit was conducted to verify the corrective action related to Audit ERC 85-104. All corrective actions have been completed satisfactorily.

V. EFFECTIVENESS The BCAP QA Program evaluated by this audit appears to be satisfactorily implemented and documented.

Vf. ATTACHMENTS None i

A4Att - b$ i-

/ Lead Tuditor /~

- hU -

' Quality Assurance Manager

[

48

5.5 REPORTS OF DEVIATION i

4 ~);(4 s C l'

, e FIELD OPERATIONS EVALUATION a00 caw nioge Turnpike CECEAUCH s#te soi Oak Ridge, Tennessee 3783o COWPOWATION (615) 482 7973 April 24, 1985 BCAP-226 Commonwealth Edison Company Braidwood Station R.R. #1, Box 81 Braceville, IL. 60a07 ATTENTION: Mr. N. N. Kaushal

SUBJECT:

ERC Observation Report BCAP-0BS-016 Gentlemen:

The Independent Expert Overview Group has reviewed the BCAP response to the subject ERC Obs.ervation Report. The corrective action taken is considered to be acceptable. This observation is considered to be closed.

Yours very truly, b Ch John L. Hansel Project Manager attach.

JLH:REH:CMT:ERM:PLC/dit cc: T. Maiman R. L. Byers N. Smith IEOG (2) Team /

Files R. N. Gardner J. G. Keppler 50

EVALUAT .

WESEAWC @ E fN PORT COWPOPA M  %

A Observation No. BCAp.nc5-016 EVALUATION RESEARCH CORP l Date April 8. 1985 OBSERVATION: During recent overinspections of electrical welding by IEOG Inspectors, the.following observations were noted which had been missed by the BCAP' Inspectors. In each case, the BCAP inspector has been shown the discrepant conditon and has concurred with tne IEOG finding as noted below:

A. As a result of an overinspection of Electrical Welding Verification Package CSR-I-E-CPH-058, the following observation was made:

Drawing No. 20E-0-3280, elevation of Detail DV-84, indicates a 1/4" fillet weld on (3) sides attaching the clip angle to the auxiliary tube steel. Contrary to this requirement, the as-built field conditon is lacking the 1/4" fillet weld on the top side of the clip a gle.

Q YEYN #AfWN & E Signature of Orignator I Date ERC / Project Man e[ Date

% 7}hs,)/4f f.L.d%gcd RESPONSE (Required by Aw/ / /9 /995- ):

See ettach:nent.

Resms- By : N 'Widtrs EVALUATION: AcceptablM Unacceptable bl uv9 M [W lR C RCA No. Issued ERC Project Manager Date CORRECTIVE ACTION VERIFIED: Sati sf actory Unsati sf actory RCA No. Issued o 4 nb $ %rS A 4lMl8(

Verified by: Date ERCProjeckManager Date OF-15.1.1 2/85 Page 1 er3 51

I Page 2 of 3 ,

BCAP-0BS-016 A. (Cont'd)

This conditon was discussed with the BCAP Task Force Inspector.

Observation CSR-I-E-CPH-058-04 was revised to indicate this conditon.

B. During overinspection of Verification Package CSR-I-E-CPH-41, the following observations were made:

Drawing No. 20E-0-3280, Detail DV84, section view, indicates a 5/16" fillet weld with one inch end returns required for the attachment of the clip angle to the structural member. Contrary to this,in the field on Hanger No. H046 the bottom end return lacks 1/16" leg size in meeting the 5/16" recuired fillet weld size. This conditon runs for 25% of the required weld length on the end return.

Drawing No. 20E-0-3263, Detail DV 1, indicates a 1/4" fillet weld 4 1/2" in length attaching the Hanger Gusset Plate to the 3/4" thick flat plate which attaches to the auxiliary steel. Contrary to this, on Hanger No. H046 the leg size of the weld on the gusset plate is 1/32" under size for the entire length of.the attachment weld.

. The above noted conditor.s were discussed with the BCAP Task Force Inspector and Observation No. CSR-I-E-CPH-41-3, was revised to indicate these conditons.

C. As a result of Overinspection of Verification Package CSR-I-E-CPH-033, the following observations were noted:

On Hanger No. 12H28-0-3121, a rejectable undercut 1/8" deep, 1/4" long is located on the end of a plate on the north leg looking North. A gouge area 1/16" deep, 1 1/2" long is located on the

. south leg looking North.

This condition was discussed with the BCAP Task Force Inspector and Observation No. CSR-I-E-CPH-033-06, was revised to indicate the conditon.

52

Page 3 of 3 BCAP-085-016 i

l D. As a result of an overinspection on Electrical Cable Pan Hanger Package CSR-I-E-CPH-054, the following observation was made:

An undercut is located on the west leg of the unistrut south face 1/32" deep, 1/16" wide and 3/16" long. Also, an undercut 1/32" deep, 1/16" side and 1/14" long was noted on the north face.

The fit-up gap on the gusset-to-plate on the west leg west face measures 1/8". The weld size is specified as 1/4". .The leg size should have been increased 1/8" to 3/8"; actual is 5/16".

This condition was discussed with the BCAP Task Force Inspector and an observation is forthcoming.

E. As a result of an overinspection on Electrical Cable Pan Hanger Welding the following observation was made:

Drawing No. 20E-0-3264, Detail DV-8, Section C-C indicates a 1/8" fillet weld on the perimeter of the unistrut attaching it to the connection member channel steel. The As Built Conditon in the field on the cable pan hangers on packages CSR-I-E-CPH-013 and CSR-I-E-CPH-032 lack the 1/8" fillet weld on the open side of the unistrut. In (3) other areas outside the ERC sample, this conditon was also noted.

Notice of Concern No.85-003 was generated on 3/19/85 on the first of the above noted conditions.

. It should be noted that NCR's (No. 708 and No. 709) have been issued which identify similar problems with Systems Controls Corp. supplied equipment; namely, the shop welds.

BCAP Observation Report CSR-I-E-CPH-013-1, was revised to include this conditon.

1 These together with those reported in Notice of Concern No's85-002 and 85-003, are creating a conce.rn within the IEOG. It is requested that BCAP respond with their basis for the aforementioned items and identify what corrective actions will be incorporated to prevent reoccurrence of these problems.

53

1 l

Attachment to ERC Observation No. BCAP-OBS-016 Page 1 of 6 l

Rrsponse to ERC Observation No. BCAP-0BS-016 is categorized into three (3) creas: Discussion. Corrective Action Taken and Corrective Action to Prevent Recurrence.

i CONDITION A Discussion:

Drawing 20E-0-3280 Detail DV-84 specifies a 1/4" fillet weld on three sides attaching the clip angle to the auxiliary tube steel. The as welded condition of the weld on the top side of the clip angle is approximately 1/8 inch undersize.

The field ccadition was not conducive for inspection of this weld and was considered inaccessible. Since the weld was inaccessible for cleaning and was not directly visible the Inspector inspected the two (2) other welds however failed to annotate the inaccessibility condition of the top weld in the remarks column on the inspection checklist.

Inspector oversight to annotate the inaccessibility condition in the remarks column on the inspection checklist.

Corrective Action Taken:

The uncleaned weld was reinspected using an inspection mirror and best measurement possible under difficult accessibility conditions. The weld was judged to be approximately 1/8" undersize.

Observation No. CSR-I-E-CPH-058-04 was revised to address the additional undersized weld.

Corree'. *.ve Action to Prevent Recurrence:

The Mechanical / Welding Level III conducted a training session for all welding inspection personnel instructing them in the following areas.

1. When accessibility conditions restrict cleaning of a weld and it is not directly visible all means must be taken to the extent possible to observe the weld for obvious unacceptable conditions and report accordingly.

2. Emphasis was placed on the importance of annotating in the remarks column when it is concluded that an inaccessibilty condition exists i which restricts cleaning or visual observation.

(1279J) 54

Atttchment to ERC Observation No. BCAP-CBS-016 Page 2 of 6 l

CONDITION B Discussion:

Drawing No. 208-0-3280, Detail DV-84 specifies a 5/16" fillet weld with one (1) inch end returns for the attachment of the clip angle to the

! structural member. The end returns on the lower side of the clip angle on Hanger No. H-046 was 1/16" undersize for 1/4" of the length of the one (1) inch weld.

Drawing No. 20E-0-3263. Detail DV-1, specifies a 1/4" fillet by 4-1/2" in length attaching the Hanger Gusset Plate to the 3/4" thick plate which attaches to the auxiliary steel. The fillet weld leg size to the Gusset Plate on Hanger No. H-046 was 1/32" undersize for the entire length of the weld.

Corrective Action Taken:

Observation No. CSR-I-E-CPH-041-3 was revised to include the additional welds judged to be undersize.

Corrective Action to Prevent Recurrence:

All discrepancies inadvertently omitted during the inspection process

!' have been brought to the involved inspectors attention with emphasis focused on exercising greater precaution during the inspection process to identify and document all observed discrepancies of this nature. No further action considered necessary.

(1279J)

, 55

i 4

AttachmInt to ERC Observation No. BCAP-OBS-016 Paga 3 of 6 CONDITION C Discussion:

Hanger No. 12H28-0-3121 contains 1/8" deep X 1/4" long undercut on the end of a plate on north leg looking North. a gouge area 1/16" deep, 1-1/2" long is located on the south leg looking North.

Seventy-two welds were inspected on this installation. Nineteen (19) were rejected of which one (1) was rejected for undercut. The inspector inadvertently omitted the additional undercut and gouge condition during the inspection process, corrective Action Taken:

Observation No. CSR-E-CFH-033-06 revised to address the undercut and gouge condition, corrective Action to Prevent Recurrence:

All discrepancies inadvertently omitted during the inspection process have been brought to the involved Inspectors attention with emphasis focused on using greater precaution during inspectiort to identify and document all observed' discrepancies of this nature. No further action required.

(1279J) 56

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

Attachment to ERC Observation No. BCAP-OBS-016 page 4 of 6 l

CONDITION D Discussion:

Undercut on the west leg of the unistrut 1/32" deep by 3/16" long and 1/32* deep by 1/4" long. On the gusset to plate weld on the west leg the required fillet weld is 1/16" undersize. A 3/8" fillet weld is required and actual is 5/16".

Eighty (80) welds were inspected on this installation. Six (6) were rejected, three for undersize (concavity) and three (3) for overlap. The discrepancies identified by ERC were inadvertently overlooked during the inspection process.

Corrective Action Taken:

Observation No. CSR-E-CPH-054-01 revised to address the additional conditions identified.

Corrective Action to Prevent:

All discrepancies inadvertently omitted during the inspection process have been brought to the involved Inspectors attention with emphasis placed on using greater precaution during inspection to identify and document all observed discrepancies of this nature. No further action considered necessary.

(1279J) 57

Attachment to ERC Observation No. BCAP-OBS-016 Paga 5 of 6 CONDITION E i Discussion:

i Drawing No. 20E-0-3264 Detail DV-8 specifies a 1/8" fillet weld on the j' outside perimeter of the unistrut attaching to the connection member j channel steel. A lack of uniform understanding of the design welding requirements and insufficient corrective action to NOC No.85-003 were '

4 identified as contributing factors to this omission.

1 i Corrective Action Taken:

I

As part of the corrective action to prevent recurrence on NOC No.85-003 a documente1 special training session for unistrut perimeter welding j

requirements was conducted on March 27, 1985 by the Mechanical / Welding 1.evel III for all inspection personnel involved with this population reinspection. However ERC Observation Report No. BCAP-08S-016 identified i one (1) additional unistrut weld length deficiency involving a different 2

BCAP Inspectcr and it was concluded that the condition was not isolated to one inspector as previously concluded during the CSR investigation of ERC NOC No.85-003.

An action plan was developed and approved by the BCAP Inspection Supervisor on April 12, 1985 to reinspect all cable pan hangers of i similar design in S&L Drawing 208-0-3263. Detail DV-3, 208-0-3264 Detail j DV-8, and 20E-0-3292, Detail DV-162 inspected prior to the special training conducted on March 27, 1985. -

} BCAP inspection personnel assigned to the reinspection effort were

{ trained on April 12, 1985 to assure a thorough understanding of the scope

of the action plan and areas requiring reinspection to satisfy design.

l Thirty-nine (39) cable pan hangers containing Details DV-3 DV-8, and DV-162 were identified to be within the scope of the action plan.

l The action plan was implemented on April 12, 1985 and completed April 15.

j 1985. A total of 238 welds, all at the open face of the unistrut, were l reinspected with 210 welds being acceptable and 28 welds unacceptable for

! weld length.

Corrective Action to Prevent Recurrence:

i

, The Mechanical / Welding Level III conducted a special training session on .

l March 27, 1985 for all Inspectors associated with this population inspection attribute reinforcing the specific requirements to satisfy design intent.

i i

i j

l (1279J) 58'

l Attachment to ERC Observation No. BCAP-OBS-016 Page 6 of 6 On April 12, 1985 a second special training session was conducted thoroughly addressing the action plan and inspection technique to be utilized by all Inspectors involved in the reinspection and future inspection assignments within this population.

Since all reinspection packages within this population containing these details completed prior to the training session conducted March 27, 1985 have been reverified, no additional corrective action is considered necessary.

1 (1279J) 59

ggsc. ['4

. FIELD OPERATIONS EVALUATION soo oaw nidge Turnoiwe W~3CEAUCH suite mi

COMPOWATION Oak Ridge. Tennessee 37830 ,

(615) 482-7973 j May 2, 1985 BCAP-235 Commonwealth Edison Company Braidwood Station R.R. *1, Box S1 Braceville, IL. 60407 ATTENTION: Mr. N. N. Kaushal SUBJECT- ERC Observation Report BCAP-0BS-017 Gentlemen:

The Independent Expert Overview Group has reviewed the BCAP response dated May 1, 1985 to ERC Observation Report No. BCAP-0BS-017. The response is considered acceptable and no further action is required.

This Observation Report is considered closed.

Yours very truly, r .

CXA%. W l John L. Hansel Prcject Manager JLH

REH:CMT/dit i

attach.

cc: T. Maiman i

R. L. Byers N. Smith l

IE0G Team!

(2) Files R. N. Gardner J. G. Keppler 60

Ap7 g%uaP c.

,d' 2 7, * "rj g 3('

EVALUATICN U" ..

WESEAECH OBSERV ATION REPORT r "- . { .g CO E POWATIO N EVA!.UAIIC.1 E23EAECri C05P.

Observation No. gcAP nAS-017 Date Anril 16_ loAC OBSERVATION: As a result of an overinspection on Structural Steel Welding Package No. CSR-I-S-002-032 for Structural Steel, Post No. 448, the following observation was made:

A. Drawing No. S-2140, Rev. U, Detail 95, section view indicates a 3/16" fillet weld 2" on each end of the 2 1/2" x 3" angle iron.

Contrary to this on the east and west side of the beam, the 2 1/2" x 3" angle iron stiffeners lack the recuired 2" fillet weld length. Refer to the attached drawing for location details.

O h 4 Signature of Orignator E 9,s 9 & b L J i d @ ules'

) ate' ERC ProjectqManager Date RESPONSE (Required by Acril 30. 1985 )

See Attachment.

Re.ss. m 32 : 2W f/dPE EVALUATION: AcceptaM

• Unacceptable O b- M Z /BI RCA No. Issued ERCProjebtManager Date CORRECTIVE ACTION VERIFIED: Sati sf actory Unsati sf actory RCA No. Issued t4 / A 2 A u nda d s7d r Verified by: Date ERCProjehtManager Date QF-15.1.1 2/c5

• 61

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

I -a:e 2-l EC4F-05 17 i

S. Oraaing No. 5-2140, Rev. U, Detail 95, sectice view ir.dicates a 1/4" fillet weld on the too and Dottom of the 2 1/2" x 3" angle iron stiffener, attaching the stiffener to the structural steel j- mem:er. Contrary to this, the east side stiffener top weld, lacks j the recuired 1/4" leg size (Top leg of the weld only). Leg size deficiency ranges from 1/32" to 1/16" for 40% of the weld length.

j This conciticn was discussed with tne BCAF Task Force Inspe:tcr.

i

! Review of the previcus conditions noted on NOC-002, 003, 004, 005, 006, t Observatien 055-016 and this Observation CBS-017, shows that 5 of the 16

'- conditions were all associated with one BCAP Task Force Inspector. With this numoer of conditions noted, ERC feels that the possibility of a r ceneric ccDie cculd exist and a reinstecticn of tre werk accccolisted by this ins:ector shculd be considered.

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! 63 -

Attichment to ERC Observation Report No. CBS-Ol7 Pcga 1 Response to ERC Observation Report No. BCAP-OBS-017 Condition A Discussion:

Reinspection Package CSR-I-S-002-032, Drawing No. S-2140. Rev. U, Detail 95 for Structural Steel Post No. 448 specifies a 3/16" fillet weld length of 2" on each end of the angle iron stiffeners to the beam attachments.

Five (5) of the eight "8" welds are less than the 2" required length.

The detail weld symbol contained two (2) different weld lengths, one on the reference line specifying a 3/16" X 1 1/2" long fillet and the second on the tail stipulating a 2" weld length. The 1 1/2" weld length was applicable to the center weld on the stiffeners with the 2" weld length required for each end weld. The BCAP Inspector inadvertently overlooked the additional information on the tail of the weld symbol and applied the 1 1/2 " length requirement specified on the reference line to all vertical welds on the stiffener.

Corrective Action Taken Observation Re' port No. CSR-I-S-002-032-3 was issued to address the insufficient weld length.

Corrective Action to Prevent Recurrence:

The BCAP Inspector was counciled to exercise more attention to details when reviewing drawings to assure all requirements are properly

! identified and executed.

Condition B i

Discussion Drawing No. G-2140, Rev. U, Detail 95 requires a 1/4" fillet weld on the top and bottom of the 2 1/2" X 3" angle' iron stiffener. The top weld on the east side stiffener is undersize from 1/32" to 1/16" for approximately 40 percent of the weld length. For visual inspection using common measuring devices dimensions are taken to the nearest 1/32" on fillet weld sizes. In this instance the BCAP inspector failed to detect the undersized weld condition of 1/32" to 1/16" identified by ERC.

1431J 64

l Attachment to ERC Observation Report No. BCAP-00BS-017 Page 2 j

i Corrective Action Taken:

Observation Report No. CSR-I-S-002-32-3 was issued to address this condition.

Corrective Action to Prevent Recurrences:

ERC Observation No. 17 has been reviewed with the responsible inspector with emphasis placed upon the importance of dimensional accuracy when measuring fillet weldsents.

ERC Concern:

In response to the ERC concern that a generic problem could potentially exist with one BCAP Inspector a two phase evaluation was conducted. The results are as follows:

Evalua* ton:

The evaluation was conducted in two phases. Phase I was to assess the individuals overall relative performance level. Phase II was an independent assessment of relative performance accuracy by a 1.evel III Welding Inspector utilizing a selected sample similar to those where ERC

, concerns were identified.

PHASE I. To arrive at the overall relative performance level considerations were given to only those packages overinspected by ERC on this Inspector and comparisons were made between the total number of welds and the number of disagreements.

The scope consisted, of seventeen (17) packages containing five hundred and twenty-three (523) welds. A total of fifteen (15) welds were in disagreement representing a 97.13%

BCM Inspector agreement. (Refer to Attachment I).

A 97.13% relative agreement is considered to be an acceptable level of proficiency.

1431J 65

Attachment to ERC Observation Report No. BCAP OBS-017 Page 3 l

PHASE II To further substantiate the individuals overall relative performance nine (9) packages were selected for the re-examination sample, all containing a similar degree of complexity as those overinspected by HRC. Six (6) packages were selected from the structural steel population. The three CPH packages represented all of the remaining un overinspected cable pan hangers inspected by this inspector. These nine (9) packages contained one hur. dred and eighty-three (183) welds outside the scope overinspected by either ERC or BCAP QA.

An independent examination was performed by the Level III Welding Inspector on all welds within the established re-examination scope. The independent examination resulted in a 100% agreement.

Conclusion Predicated on the results of our evaluation there was no ind*catf a of a generic problem to exist with this individual. Our overall ra ' /.sion is that no generic concern exists and the individuals performants evel is within acceptable limits. No further action is considered necessary.

}uns f.!

)

1431J 66 ,

_. . .__ _ _ a

(

i Attachment I l RIsponse to ERC Obsarvation BCAP-OBS-017 l I

PHASE I ERC overinspection Comparisons Total number of welds (17 Reinspection Packages) 523 Welds

! Total number of welds accepted by BCAP Inspector 439 84.9%

Total Number of welds rejected by BCAP Inspector 84 16.1%

Total number of welds in agreement by ERC 508 97.13%

Total number of welds in disagreement by ERC 15 2.87%

ERC Results were 97.13% in agreement with the DCAP Inspector results representing a 97.13% inspector relative accuracy rate.

1 i

e 1431J 67

AttKchment II Response to ERC Obssrvation BCAP-OBS-017 PHASE II RB-EXAMINATION SCOPE PACKAGES NO. OF WELDS CSR-I-S-002-021 18 CSR-I-S-002-026 12 CSR-I-S-002-058 10 CSR-I-S-002-117 19 CSR-I-S-002-i19 5 CSR-I-S-002-126 9 CSR-I-E-CPH-046 10 CSR-I-E-CPH-050 64 CSR-I-E-CPH-052 36 TOTALS 9 PACKAGES 183

& S I

1431J 68

l 4. a o.t kaluatien O F ,

l

$esearth A Ip01~dtion I l l

July 2, 1985 BCAP-289 Coninonwealth Edison Company Braidwood Station R.R. #1, Box 81 Braceville, IL. 60407 ATTENTION: Mr. N. N. Kaushal Mr. N. P. Smith

REFERENCE:

1. BCAP response to BCAP-0B5'-018 dated 6/24/85, signed by R. L. Byers.

2. Letter, N. P. Smith to ERC, subject, "ERC Observation Report BCAF-0BS-018", dated June 28, 1985, BRD #16.607.

~

Genticmen: .

The Independent Expert Overview Group has reviewe'd the responses of Reference 1 and Reference 2 to the subject observation. Both responses are acceptable and no further action is reovired. This observation is considered closed. A copy of the observation form signed-to signify closure is attached for your records.

Very truly yours, .

y '. g/f h l-Jane L. Hanse -

Project Manager attacn.

JLH:WLC:PLC/dit cc: T. Maiman R. L. Byers IE03 Team (2) Files!

R. N. Gardner J. G. Keppler 69 f Oak Ridge Tumpike Suite 501 Oak Ridge, Tennessee 37830 (615) 482 7973

EVALUATION WESEACCH 035ER)AliON REPORT

& f sS Observ ation No. Brac.noc.n1B JUN 2 51985 Date June 20, 1985 m,m,m,._

sc^rard COR".

OBSERVATION: dIthe'lesuitofanoverinspectionofVerificationPackage No. CSR-I-E-EIN-049 (Junction Box No. lJB508A), the following observation tras made:

Attricute 3d. " Stiffeners" was documented on tne checklist as being N/A by the inspector. This attribute should have beer, either accepted or rejected since the Junction Box Connection.

Detail recuires that stiffeners be installed (Ref: 5&L Drawing No. 20E-0-3393C, Type SS3C). In this case, tne inseector sheuld have dispositiored the attri ute as

":iefe: ed" sic:e tne st f ife 1ers e e .:: ins a'lec.

(Cor.tinued next oace) sYhA 8 b $dS~

$Y2MYS 4'd % -

l lM b3~

1. Signatu/e of Orignator Date ERC[roect-Manag 'Date

& hAMJA J.L.4 W tb W8 RESDONSE (Required by JulV 3, /965 ):

See Attachment. ,

B Y. 2 W- 6/29ltS eta'.ur *LN: Acce p ta b'. e U".a: c e p t abl e h b

/ 'I RCA hr. Issuec

' ER' E":je:k M3*.a;f" . Da:E Satisf actory CORRECTIVE ACTION YERIFIED:

{ ] Ur.sati sf a: tory RCA N. Issuec k ?b -

. v. os b i a . '.L & l 7- b /R grif4ec4y:'" / oa4 ERC Projed Manager Date 1

?:

70

age 2

- ECAF-055-:',E A revie'* c' the results of BCAP-QA Overinspectior o' tre above pa:* age 5 On: taa; tee ir.sce:: r performinc ne overinsce:t' - also dist:5'tiored the above attribute as N/A. The inspector should have rejected this attribute, since the stiffeners were n0t installed.

o D

e e

9 O O l

1 71

Attachment to ERC Observation No. BCAP-OBS-018 Page 1 of 2 Response to ERC Observation No. BCAP-OBS-018 is categorized into three (3)

Creas: Discussion, Corrective Action Taken, and Corrective Action to Prevent Recurrence.

DISCUSSION On Reinspection Package No. CSR-I-R-EIN-049 (Junction Box po. IJB508A)

Attribute 3d. " Stiffeners" was incorrectly documented on the checklist as not applicable.

Predicated on the similarity between the Junction Box Supports and conduit / Cable Pan Supports it was the understanding of the CSR Electrical Inspectors that stiffeners were not required for the following reason:

Conduit and Cable Pan Supports contain a hanger tabulation drawings which specifically identify supports for stiffener applicability whereas the Junction Box List Drawings does not. Based upon the fact that the Junction Box List did not specify where stiffeners were required it was misinterpreted that stiffeners were not applicable. This interpretation was contrary to the requirements specified on the applicable drawing detail. .

It was concluded that this was a misinterpretation of the installation requirements delineated on Dr awing 20-E-0-3393C, Rev. AA. details for citernate support connection to structural steel.

CORRECTIVE ACTIOW TAKEN There were a total of one hundred and thirty-eight (138) Reinspection Packages within the Electrical Equipment (EIN) Populations. Considerations for ovaluation was only directed to Reinspection Packages containing Junctior, Boxes, since stiffeners would only have a potential to apply in this installation category.

A total of seventy-eight (78) Reinspection Packages contained Junction Box Equipment. A thorough evaluation of these packages was conducted to determine stiffener applicability. In addition to the package identified in this observation two additional packages, CSE-1-E-EIN-027 and CSE-1-E-EIN- 149 were determined to be installations requiring stiffeners. Checklist Attribute 3d Wds N/A'd in both instances and Field Reverification revealed stiffeners were not installed. Documentation was corrected to refle:t proper hardware status and observation reports written on the one (1) Reinspection Package identified by ERC and two (2) additional packages identified ar a result of the evaluation. Corrective action was completed on June 18, 1985.

1767J 72 i

Attachment to ERC Observation BCAP-OBS-018 Page 2 of 2 In as much as the total population sample has been completely reviewed by CSR Electrical Inspection no further corrective action is considered necessary.

CORRBCTIVE ACTION to PRgVENT RECURRENCE All electrical inspectors have been made aware of the correct interpretation cf the requirements of drawing 20-E-0-3393C.

hv/rs O

e 9

l'16 13 73

i June IE. 19EE BR #16.607 i

1 Evaluation Research Corporation 800 Oak Ridge Turnpike C i d '

Suite 501 Oak Ridge. Tennessee 378830 JUL 0 2195g-ATTENTION: Mr. J. L. Hansel EVALUATION RESEARCn CORP.

Project Manager

SUBJECT:

EEC Observation Report BCAP-OBS-018

REFERENCE:

(a) BCAP response to subject observation dated 6-24-85

Dear Sir:

BCAP Q.A. has reviewed reference (a) and of f ers an additional comment in response to the last paragraph of your observation which stated:

"A review of the results of BCAP Q.A. Overinspection of the above package shows that the inspector performing the overinspection also dispositioned the above attribtte as N/A.

The inspector should have rejected this attribute. since the stiffeners were not installed."

C:m c .

The BCAP Q.A. inspector performing the overinspectiet of pcpulat;cn iter CSR-I-R-EIN-049 (Junctiot Box Nc. 1JB505A) similar'y .

misinterpreted the installation requirement's delineated and inectrectly documented Attribute 3d " S t i f f e n e r s as not applicat'.e (NA).

Tnts was the only itet overinspected by BCAP Q.A. relating to this attribute. requirement. BCAP Q.A. O/0 Group corrected the checklist in the CSR-I-P-EIN.049 validation package te reflect tne*

proper hardware status and documented agreement with the referenced BCAP Tast. Force observation. This corrective action was cen;;etef on June 27, 1985.

The O/0 Group electrical inspectors have been made aware of the correct interpretation of the requirements per the discussion in reference (a).

.D 74

BE! e16,6t? Page 2 If you have further questions regarding this letter, please contact the BCAP Q.A. office (x2635).

Very respectfully, N. P. Smith General Supervisor Q.A. -

NPS/WML/n1w (0522B) ec: T. J. Maimac N. N. Kaushal R. L. Byers .

R. N. Gardner '

ERC Trailer #6 -

O. A. File - 71.7 69.60.2.3 75

Origina. 'AT Otservaticn Re:Ordle) l is being processed in at:cria:'.~e j uith BCAP-06. l A cc 7 cf the BCAP Observation Remrd KAr OesuvAT w h m(ci :is attached.

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10. DESCRIPTICE OF OBSEFVATICW:

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le being processed in accordance with BCAP-06.

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1. OsSERVATICW No.C'3R .'f -E - EIAl-O H -OL LART 1 CBSERVATION IDENTIFICATION & DesCRIPTICW

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l. SYSTEM (if known): / 5. CHECKLIST / ITEM wo.

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10. DESCSIPTION OF OBSERVATION:

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Signatur/ Da' PAPT 2 OBSERVATION CLARITY, COMPLETENESS. AND ACCURACY REVIEV 12.CNs /C1).F I FICATION : M-NJ l

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Page 1 of 3

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PAPT 2 OBSERVATION CLM ITY, COMPLETENESS. AND ACCURACY REVIEV

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13. SUITABLE FOR FURTHER PROCESSING: gyg 14.REVIEVED  :

w L-Lo-g S k.ature Dat Vh.? FC:n Ot.-1 (Ft.. Li 78

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