ML20211H282
| ML20211H282 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/18/1985 |
| From: | Miosi A COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20211H263 | List: |
| References | |
| 0792K, 792K, NUDOCS 8606230436 | |
| Download: ML20211H282 (92) | |
Text
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O one First National Plate. Chicago lihnoit Commonwealth Edison Address Reply to: Post Office Bon 767 Chicago. Illinois 800%
PRICRifY f.03TIb6 Wi _
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October 18, 1985 bh
- -An flLQs Mr. James G. Keppler Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL. 60137
Subject:
BCAP Presentation at Glen Ellyn on October 15, 1985
Dear Mr. Keppler:
The purpose of this letter is to document Commonwealth Edison Company's presentation at Glen Ellyn on October 15, 1985 to you, members of your staf f, and representatives of NRR and OELD.
Enclosed please find copies of the transparencies used to report BCAP results.
Very truly yours, A. D.
losi Nuclear Licensing Administrator ADM/klj Enclosure cc:
J. Stevens 0792K B606230436 860609 oui 2 i n-PDR ADOCK 05000456 G
Encicsu2e 1 FINAL BCAP PUBLIC ME'FTING AGFNDA INTRODUCTION TOM MAIMAN BCAP PROGRAM DESCRIPTION BCAP RESULTS (GENERAL)
PROJECT CONCLUSIONS (GENERAL)
D BCAP DETAILS AND SPECIFICS BY FI FMFNT NINU KAUSHAL CSR RPSR RSCAP BREAK--
BCAP QUALITY ASSURANCF GENE FITZPATRICK i
BCAP INDEPENDENT EXPERT OVERVIEW GROUP JOHN HANSEL
SUMMARY
TOM MAIMAN 7
Page 2 of 17 BCAP PURPOSE PROGRAM 0F INSPECTIONS AND REVIEWS UNDERTAKEN AS A PRUDENT MEASURE TO ANSWER ANY LEGITIMATE QUESTIONS CONCERNING THE OVERALL QUALITY OF CONSTRUCTION AT THE BRAIDWOOD STATION BCAP IS IN ADDITI0fi TO THE IMPLEMENTATION OF EDISON'S EXISTING QUALITY CONTROL AND QUALITY ASSURANCE PROGRAMS 9
BCAP PROVIDES A SEPARATE BASIS FOR CONFIDENCE IN CONSTRUCTION QUALITY.
PRIMARY BASIS FOR CONFIDENCE REMAINS WITH THE EXISTING QUALITY CONTROL AND QUALITY ASSURANCE PROGRAMS.
i e
l Page 3 of 17 QBJECTIVES OF BCAP TO PROVIDE FURTHER ASSURANCE THAT:
(
THERE ARE NO PROGRAMMATIC DESIGN SIGNIFICANT PROBLEMS IN THE CONSTRUCTION OF BRAIDWOOD WHICH HAVE NOT BEEN IDENTIFIED AND ADDRESSED CSR CONSTRUCTION SAMPLE REINSPECTION THE ON-SITE CONTRACTORS' PROCEDURES GOVERNING THE 9
ONGOING SAFETY-RELATED CONSTRUCTION AND QUALITY ASSURANCE ACTIVITIES ADDRESS ALL APPLICABLE DESIGN AND REGULATORY REQUIREMENTS RPSR REVERIFICATION OF PROCEDURES TO SPECIFICATION REQUIREMENTS WHERE PAST CONSTRUCTION PROBLEMS HAVE BEEN IDENTIFIED WHICH RESULTED IN SIGNIFICANT CORRECTIVE ACTIONS, SUCH CORRECTIVE ACTIONS WERE OR WILL BE EFFECTIVELY IMPLEMENTED AND DOCUMENTED REVIEW OF SIGNIFICANT CORRECTION RSCAP ACTION PROGRAMS m-#
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i Page 4 of 17 PROGRAM FI FMENTS CSR CONSTRUCTION SAMPLE REINSPECTION A SAMPLE OF THE CONSTRUCTION WORK COMPLETED PRIOR TO JUNE 30, 1984 IS REINSPECTED AND THE ASSOCIATED QUALITY DOCUMENTATION IS REVIEWED FOR COMPLETENESS AND ACCURACY RPSR REVERIFICATION OF PROCEDURES TO SPECIFICATION REQUIREMENTS CONTRACTOR PROCEDURES IN EXISTENCE ON JUNE 9
30, 1984 AND GOVERNING ONGOING SAFETY-RELATED CONSTRUCTION AND QUALITY ASSURANCE ACTIVITIES ARE REVIEWED TO ASSURE THAT THESE PROCEDURES ADDRESS ALL APPLICABLE DESIGN AND REGULATORY REQUIREMENTS RSCAP REVIEW 0F SIGNIFICANT CORRECTIVE ACTION PROGRAMS THE IMPLEMENTATION, METHODOLOGIES, AND RESULTING DOCUMENTATION ASSOCIATED WITH SPECIFIC SIGNIFICANT CORRECTIVE ACTION PROGRAMS IDENTIFIED PRIOR TO JUNE 30, 1984 ARE REVIEWED TO ASSURE THAT THESE SPECIFIC AREAS OF CONSTRUCTION ARE OF ACCEPTABLE QUALITY l
l
Page 5 of 17 BCAP ORGANIZATIONAL CHART Commonwealth Edison Company Chairman and President l
Manager of Manager of Projects Quality Assurance 9
Independent Expert overview j
Group 1
l Assistant Manager Braiduced Quality Assurance Project Manager Site M General Rasv.
BCRP Director BChr 94 BCRP Task Force Overview Group e
e Pago 6 of 17 BCAP TASK FORCE BCAP TASK FORCE SPECIFICALLY ORGANIZED IN JUNE, 1984. TO IMPLEMENT BCAP ACTIVITIES.
HEADED BY COMMONWEALTH EDIS0N COMPANY AND SUPPORTED BY SARGENT AND LUNDY ALONG WITH OTHER CONSULTANTS.
STONE AND WEBSTER AND DANIEL CONSTRUCTION COMPRISE MAJORITY OF THE TASK FORCE.
ALL BCAP PERSONNEL DEDICATED TOTALLY TO BCAP.
BCAP PERSONNEL HAVE HAD NO PRIOR RESPONSIBILITY FOR THE CONSTRUCTION ACTIVITIES BEING VERIFIED.
l MANPOWER PEAKED AT 122 PERSONS.
EXPERIENCE LEVEL AVERAGED:
17.7 YEARS ENGINEERS I
8.9 YEARS INSPECTORS REQUIRED 109 MANYEARS OF EFFORT.
Page 7 of 17 OUALITY ASSURANCE COMMONWEALTH EDISON COMPANY COMMITTED THAT BCAP WAS l
TO BE CONDUCTED UNDER THE COMMONWEALTH EDIS0N COMPANY QUALITY ASSURANCE PROGRAM.
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6 BCAP QUALITY WAS OVERVIEWED BY A SEPARATE DEDICATED QUALITY ASSURANCE GROUP.
BCAP QUALITY ASSURANCE PERSONNEL HAD NO PRIOR RESPONSIBILITY FOR BRAIDWOOD CONSTRUCTION ACTIVITIES.
o MANPOWER PEAKED AT 21 PERSONS.
EXPERIENCE LEVEL AVERAGED:
ENGINEERS 21.9 YEARS INSPECTORS 11.6 YEARS 1
e REQUIRED 20 MANYEARS OF EFFORT.
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Page 8 of 17 INDEPENDENT EXPERT OVERVIEW GROUP (IEOG)
COMMONWEALTH EDISON COMPANY RETAINED JOHN HANSEL TO HEAD A TEAM OF EXPERTS TO PROVIDE AN INDEPENDENT OVERVIEW 0F BCAP.
TWO 0F THE IE0G PRINCIPALS PARTICIPATED IN THE REVIEW 0F A 1984 NRC REPORT TO CONGRESS TITLED " IMPROVING QUALITY AND THE ASSURANCE OF QUALITY IN THE DESIGN AND CONSTRUCTION OF NUCLEAR POWER PLANTS."
THERE IS AN ON-SITE STAFF REPORTING TO THE IE0G.
THE IEOG FUNCTIONS UNDER A PROTOCOL APPROVED BY THE NRC.
THE INDEPENDENT EXPERT OVERVIEW GROUP OVERVIEWS ALL BCAP ACTIVITIES TO ASSURE THAT BCAP IS MEETING ITS OBJECTIVES BY:
REVIEWING OVERALL PLANS, PROCEDURES AND IMPLEMENTING INSTRUCTIONS REVIEWING AND MONITORING THE BCAP QUALITY ASSURANCE PROGRAM MONITORING IMPLEMENTATION OF THE PROGRAM BY CONDUCTING AUDITS, SURVEILLANCES AND OVERINSPECTIONS
Enclocuro 1 Page 9 of 17 IEOG EXPERIENCE
SUMMARY
AERAGE PRE-BCAP EXPERIENCE IQIAL NUCIFAR SENIOR EXPERTS 37.0 27.3 ENGINEERING (TOTAL) 30.3 21.6 QUALITY ASSURANCE ENGINEERING 22.8 19.0 INSPECTORS 16.3 7.8 9
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l Page 10 of 17 contraeter I
E41351 PRtMECT Craft Skills Design / angi.eering Specification IEWRCWWWT Production
- Procurseent canttols Construction Mg=:.
4XBffRCLS Inspections, :c Testing / Start-up I I 9
M M
Page 11 of 17 Contractor g
PROJECT Craft Skills Design / Engineering IguiACEMENT Production j
specification Centrols j
Procurament CONTROLS Inspections, 0.c construction Mgn.
construction QA Testing / start-up 1
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Page 12 of 17 coritraetor 5413 s1 PROJECT Craft Skills Design / Engineering IgupCSEbff Production Sp.cification Centrals Procurseent Cl3fTROLS Inspections. ;.0 Construction Mg::.
Construction QA Testing / start-up I f l
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- a8918R Specialist IIOG I
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- WE Van Task Force Inspectice achp p Indepeed st Overview i I
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- Audit
- Serve 111ance
Page 13 of 17 BCAP RFSULTS CSR RESULTS:
REPRESENTS THE MAJOR PORTION OF THE BCAP EFFORT SAMPLE COVERED:
4 CONSTRUCTION DISCIPLINES 650,000 28 INSPECTION CATEGORIES INSPECTION 365 INSPECTION ATTRIBUTES POINTS 2,600 INSPECTION ITEMS NO DESIGN SIGNIFICANT DISCREPANCIES IDENTIFIED.
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l Page 14 of 17 1-l CSR RESULTS CONT'D 1
THE ENGINEERING ANALYSIS FOR EACH CSR IDENTIFIED DISCREPANCY SHOWED THAT THE DEFICIENCIES WERE NOT DESIGN SIGNIFICANT.
BCAP CSR RECOMMENDATIONS BCAP RECOMMENDED THAT SPECIFIC DISCREPANCIES WITH RESPECT TO 5 CONSTRUCTION ATTRIBUTES (0UT OF 365)
WARRANTED FOLLOW-UP ACTION TO FURTHER ENHANCE CONFIDENCE IN THE QUALITY OF CONSTRUCTION FOR THOSE 9
PARTICULAR ATTRIBUTES.
ADDITIONALLY, BCAP IDENTIFIED 2 DOCUMENTATION DEFICIENCIES FOR WHICH FURTHER REVIEW WAS ALSO RECOMMENDED.
NONE OF THESE LED TO DESIGN SIGNIFICANT DISCREPANCIES IN THE SAMPLE.
THESE RECOMMENDATIONS WERE IN ACCORDANCE WITH BCAP'S COMMITMENT TO IDENTIFY POSSIBLE "SIGNIFICANT CONDITIONS ADVERSE TO QUALITY."
PROJECT RESPONSE THE PROJECT WILL IDENTIFY AND REPAIR ANY OF THESE ATTRIBUTE DEFICIENCIES AS NEEDED THROUGHOUT THE PLANT.
Page 15 of 17 i.
CSR PROJECT RESPONSE CONT'D ADDITIONALLY, A NUMBER OF OTHER IDENTIFIED DISCREPANCIES, FOR WHICH BCAP MADE NO RECOMMENDATIONS BECAUSE THE DISCREPANCIES WERE INSIGNIFICANT TO DESIGN, WILL ALSO BE REPAIRED.
THIS IS BEING DONE MAINLY FOR REASONS OF APPEARANCE IN ACCORDANCE WITH GOOD CONSTRUCTION PRACTICE.
EXAMPLES:
LOOSE NUTS AND BOLTS MISSING CLAMPS CONDUIT SEGREGATION CODE LABELS LOOSE FLEX CONDUIT CONNECTIONS THE PROJECT WILL ALSO REVIEW THE 2 DOCUMENT DEFICIENCIES FOR PAST WORK.
DISPOSITION IS EXPECTED TO BE ACCOMPLISHED ~THROUGH USE OF EXISTING ALTERNATIVE DOCUMENTATION OR SAMPLE VERIFICATION OR BOTH.
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Page 16 of 17 BCAP RESULTS CONT'D P2SR COVERED 592 CONTRACTOR PROCEDURES CONTRACTOR PROCEDURES FOR ONG0ING WORK ADEQUATELY ADDRESS THE DESIGN AND REGULATORY REQUIREMENTS.
9 COVERED 11 CORRECTIVE ACTION PROGRAMS THE CORRECTIVE ACTION PROGRAMS WERE OR WILL BE EFFECTIVELY IMPLEMENTED AND DOCUMENTED.
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Page 17 of 17 CONCLUSIONS CSR PROJECT HAS HIGH CONFIDENCE THAT THE BRAIDWOOD CONSTRUCTION MEETS DESIGN AND REGULATORY REQUIREMENTS.
CONFIDENCE WITH RESPECT TO 5 CONSTRUCTION ATTRIBUTES AND 2 DOCUMENTATION DEFICIENCIES IDENTIFIED BY BCAP CAN BE ENHANCED BY FOLLOWING UP ON THE BCAP RECOMMENDATIONS (IN PROGRESS).
1 RESR PROJECT HAS HIGH CONFIDENCE THAT ONGOING WORK WILL MEET DESIGN AND REGULATORY REQUIREMENTS.
J PROJECT HAS HIGH CONFIDENCE THAT CORRECTIVE ACTION 4
PROGRAMS WHERE NEEDED WERE'OR WILL BE EFFECTIVELY IMPLEMENTED AND DOCUMENTED.
l QVERALL PROJECT HAS HIGH CONFIDENCE, BASED ON ITS EXISTING QUALITY CONTROL AND QUALITY ASSURANCE PROGRAMS AND NOW AS SUPPLEMENTED BY THE BCAP RESULTS, THAT PLANT CONSTRUCTION IS AND WILL CONTINUE TO BE GOOD.
i
E n c l o s u r e -3 Page 1 of 2 BCAP QUAL ITY ASSURANCE KEY OBJECTIVE i
e ASSURE BCAP CONFORMED WITH APPLICABLE CECO QUALITY ASSURANCE PROGRAM REQUIREMENTS AND INDUSTRY QUALITY STANDARDS SUPPORTING OBJECTIVES 1
9 ASSURE TASK FORCE ESTABLISHED AND MAINTAINED ADEQUATE MANAGEMENT CONTROLS THROUGHOUT BCAP S
ASSURE TASK FORCE PERFORMED ACTIVITIES IN CONFORMANCE j
WITH APPROVED PROGRAM, PLANS AND IMPLEMENTING PROCEDURES j
i METHODOLOGY 9
ESTABLISHED BCAP QUALITY ASSURANCE PLAN AND IMPLEMENTING PROCEDURES S
APPLIED BASIC Q.A. FUNCTIONS TO ACCOMPLISH THE OBJECTIVES
- AUDIT
- SURVEILLANCE
- DOCUMENT REVIEW
- OVERINSPECTION l
l Page 2 of 2 BCAP QUALITY ASSURANCE CONCLUSIONS S
BCAP TASK FORCE ESTABLISHED AND MAINTAINED ADEQUATE MANAGEMENT CONTROLS THROUGHOUT BCAP O
BCAP TASK FORCE ACHIEVED AN EXTREMELY HIGH LEVEL OF CONFORMANCE TO NUMEROUS DETAILED REQUIREMENTS IN IMPLEMENTATION o
O BCAP WAS CONDUCTED IN CONFORMANCE WITH THE APPLICABLE QUALITY ASSURANCE PROGRAM REQUIREMENTS AND INDUSTRY QUALITY STANDARDS i
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PRESENTATION by j
INDEPENDENT EXPERT OVERVIEW GROUP l
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October 15, 1985 n
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IE0G Organization l
o Requirements for IE0G - BCAP Policy i
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Requirements for IE0G - CECO /NRC letter dated 8/30/84 tal n
o Conclusions drawn by IE0G mi j
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I 10/15/85
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i IEOG ORGANIZATION f
PROJECT MANAGER J. L. Hansel j
Quality Assurance
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DEPUTY PROJECT MANAGER I
R. E. Ham I
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l Mechanical / Piping Electrical HVAC Civ11/Structura1 Audits / Inspection W. L. Chase M. A. Petrick R. V. Laney C. H. Brown, Jr.
A. E. Cocoros D
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Records Management C
C. M. Thoseson i
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CSR I
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Page 5 of 22 J
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" Conducting an overall review of the BCAP scope document objectives and a review of each of the 3 CAP elements to determine if the BCAP elements will fulfill their objectives."
All scope and plan documents, and all revisions were reviewed.
All comments satisfactorily i
resolved.
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10/15/85 l
Page 6 of 22 t
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" Ascertaining if the BCAP effort as o
identified in the scope documents is properly focused and whether the goals of the BCAP are being 2
fulfilled."
Reviewed all scope and plan l
documents, and all procedures
!o and checklists to assure that ll the program was properly focused to achieve its' goals.
IE0G comments were resolved.
1 Performed independent inspections, 1
audits and surveillances to ensure compliance with Program requirements.
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10/15/85
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" Conducting audits that will address the implementation of each of.the t
BCAP elements.
Items to be specifically audited will be ad-herance to Program procedures, evaluation of Quality Assurance i
involvement, qualifications of j
the personnel performing inspections, and identification l
of nonconformances and adequacy of the corrective actions."
Conducted five audits of BCAP and six audits of BCAP QA.
Twelve findings issued and resolved.
o Participated in eleven over-views of'BCAP QA audits.
i Monitored BCAP activities to l
ensure BCAP inspectors were qualifidd, tested and certified.
i Audited BCAP QA to ensure over-view /overinspection inspectors were qualified, tested and' j
certified.
Maintained a system to document /
resolve issues and concerns.
i 18 Observations - All resolved 6 Notices of Concern - All resolved I
10/15/85 i
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" Performing an independent review of selected BCAP identified dis-crepancies to provide assurance l
that the engineering evaluation for design significance was adequately performed and documented."
Reviewed approxima'tely 2,300 BCAP Observations and reviews conducted by S & L for design significance.
IE0G concerns were adequately resolved.
Reviewed approximately 25% of the calculations supporting S & L evaluations and found them to be acceptable.
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"---performing field inspections, i
1 audits and surveillances of installed equipment, hardware l
and in-process inspections-- "
Utilized Level III inspectors certified to ANSI N45.2.6.
I Overinspected and performed surveillance on BCAP and BCAP QA inspectors.
320 Overinspections l
105 Documentation Reviews 21 Surveillances IEOG Observations and Notices of Concern (NOC) were issued.
All resolved.
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Page 11 of 22 4
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"---Issue Monthly Reports-- "
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Monthly status reports issued September 1984 through July, 1985.
Documented IE0G activities and progress i
evaluations.
Distribution included the Nuclear Regulatory Commission.
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Produced Interim Reports i
March - September 1984 October - December 1984 January - March 1985 April - June 1985 1
Final Report is planned for November 1985.
10/15/85
Page 12 of 22 I
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"---review some observations to assure that appropriate ones are l
being documented as discrepancies (NCR's)."
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i On distribution for all observations transmitted to the site Project Construction Department for pre-paration of NCR's.
IE0G received copies of all NCR's to allow for l
a review to ensure adequate resolution of the observation.
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Page 13 of 22 o
"---review of sampling of implementing procedures of the Quality Assurance Overview Group."
The IE0G reviewed and concurred d
with all BCAP QA procedures.
In addition, the IE0G performed six audits of BCAP QA to ensure adequate implementation of the o
procedures.
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"---review a sampling of discrepancies for which design calculations were performed by the A/E to support their evaluation for design significance-- "
The IEOG reviewed in excess l
of 2300 observations and S & L l
rationale for determining an 9
observation to be non-design i
significant.
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25% of the calculations per-l formed by S & L in support of their evaluation to determine 1
l design significance.'
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Page 15 of 22
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Page 16 of 22 l
o The purposes of CSR was to:
reinspect a significant sample of completed safety-related work to verify conformance to design requirements.
review the quality documentation for the sample reinspected to assure that is is complete and accurate.
demonstrate with high confidence that there are no programmatic design-significant discrepancies i n the construction of the plant.
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I Based on the IE0G overview of CSR we believe:
1.
The CSR was programmatically designed to fulfill the stated purposes.
2.
The CSR program was imple-mented in accordance with established program documents and procedures.
3.
As a result, the conclusions i
drawn by CSR can be supported.
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52l$IPlr'22 The purpose of RPSR was to assure that on-site contractors' procedures effective as of June'30, 1984 governing ongoing safety-related construction and quality assurance activities, address all applicable design and regulatory requirements.
10/15/85
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5%$IMr'22 It is the conclusion of the IE0G that:
1.
The RPSR program was programmatically sound to achieve its purpose.
2.
The implementation of the RPSR program was implemented in accordance with established program documents and procedures.
3.
The results achieved by the RPSR program provide a sound basis for proceeding with construction.
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Page 20 of 22 The objective of RSCAP was to assure that where past construction problems have been identified which resulted in significant corrective actions, these corrective action programs have been adequately implemented.
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Based on the IE0G overview of RSCAP activities, the following may be concluded:
1.
RSCAP was programmatically sound to accomplish its objective.
2.
The implementation of the RSCAP program followed the programmatic requirements.
o 3.
The review by RSCAP of the imple-mentation of the significant corrective action programs was thorough.
The RSCAP review resulted in strengthening the implementation of several significant corrective action programs.
10/15/85
Page 22 of 22 OVERALL ASSESSMENT It is the conclusion of the IEOG that the BCAP achieved the goals and the purposes delineated in the BCAP Policy, BCAP Over-view Plan and the three Element Plans.
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Page 1 of 2
SUMMARY
BCAP, A PROGRAM OF SAMPLE REINSPECTIONS AND REVIEWS COVERING SAFETY-RELATED CONSTRUCTION ACTIVITIES, WAS UNDERTAKEN AS A PRUDENT MEASURE TO ANSWER ANY LEGITIMATE QUESTIONS CONCERNING QUALITY OF CONSTRUCTION.
j IT HAS BEEN AMONG THE LARGEST, MOST COMPREHENSIVELY ORGANIZED AND PROFESSIONALLY EXECUTED IN THE INDUSTRY.
HCAE REQUIRED 109 MANYEARS OF EFFORT LOOKED AT OVER 650,000 INSPECTION POINTS 9
REVIEWED 592 CONTRACTOR PROCEDURES VERIFIED 11 CORRECTIVE ACTION PROGRAMS BCAP RFSULTS:
NO DESIGN SIGNIFICANT DISCREPANCIES IN PAST WORK WERE IDENTIFIED.
CONTRACTOR PROCEDURES ADEQUATELY ADDRESS ALL DESIGN AND REGULATORY REQUIREMENTS.
THE 11 CORRECTIVE ACTION PROGRAMS WERE OR WILL BE EFFECTIVELY IMPLEMENTED AND DOCUMENTED.
l Page 2 of 2 PROJFCT CONCLUSIONS:
BCAP OBJECTIVES, ORGANIZATION, STAFFING, CONDUCT, OVERVIEW AND DOCUMENTATION LEAD TO OVERALL VALID, MEANINGFUL AND DEPENDABLE RESULTS.
EDIS0N HAS HIGH CONFIDENCE THAT ALL WORK, PAST AND ONG0ING, WILL RESULT IN COMPLETED SYSTEMS THAT ARE ADEQUATE TO PERFORM THEIR SAFETY-RELATED FUNCTIONS.
BRAIDWOOD PLANT WHEN COMPLETE WILL MEET ALL REGULATORY REQUIREMENTS.
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(1825D) l Page 1 of 48 CONSTRUCTION SAMPLE. REINSPECTION (CSR)
OBJECTIVES i
METHODOLOGY RESULTS o
CONCLUSIONS (2072J)
Page 2 of 48 CSR (CONSTRUCTION SAMPLE REINSPECTION) OBJECTIVE REINSPECT A SUFFICIENT SAMPLE OF ON-SITE COMPLETED, SAFETY-RELATED CONSTRUCTION ACTIVITIES TO VERIFY
)
CONFORMANCE TO DESIGN.
REVIEW DOCUMENTATION FOR THE SAMPLE REINSPECTED TO ASSURE THAT IT IS COMPLETE AND ACdVRATE.
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l (2072J) i Page 2 of 48 CSR (CONSTRUCTION SAMPLE REINSPECTION) OBJECTIVE REINSPECT A SUFFICIENT SAMPLE OF ON-SITE COMPLETED, SAFETY-RELATED CONSTRUCTION ACTIVITIES TO VERIFY
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CONFORMANCE TO DESIGN.
REVIEW DOCUMENTATION FOR THE SAMPLE REINSPECTED TO ASSURE THAT IT IS COMPLETE AND ACCURATE.
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CSR MAJOR ACTIVITIES ESTABLISH CONSTRUCTION INSPECTOR CATEGORIES AND CERTIFICATION POPULATIONS DEVELOP SELECT CHECKLISTS /
SAMPLES l
INSTRUCTIONS I
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PREPARE l
VERIFICATION o
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REINSPECTION /
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REVIEW I
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OBSERVATIONS I
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SAMPLE EVALUATE I- - - -
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FINAL REPORT (2072J)
Page 4 of 48
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ESTABLISHMFNT OF CONSTRUCTION CATEGORIES AND POPULATION ITEMS CONSTRUCTION CATEGORIES WERE ESTABLISHED BASED ON GROUPS OF SAFETY-RELATED HARDWARE ITEMS CONSTRUCTED USING SIMILAR PROCESSES OR CONTAINING SIMILAR TYPE OF COMPONENTS THIRTY CONSTRUCTION CATEGORIES IDENTIFIED POPULATION IN EACH CATEGORY SUBJECT TO CSR ENCOMPASSED
+
WORK WHICH WAS:
0 PERFORMED ON-SITE SAFETY RELATED COMPLETED QC ACCEPTED AS OF JUNE 30, 1984 l
(2072J)
Page 5 of 48 CSR SAMPLE SFLFCTION i
I MHS TOTAL POPULATION 1
i (NOT TO SCALE) l TOTAL SAMPLE FOR EACH CATEGORY CONSISTED OF THREE PARTS 1.
RANDOM (RN)
CHOSEN SUCH THAT EACH ITEM HAS AN EQUAL CHANCE OF INCLUSION.
THE SIZE OF THIS SAMPLE PORTION IS SUFFICIENT TO CONCLUDE WITH 95% CONFIDENCE 9
THAT AT LEAST 95% OF POPULATION IS FREE OF DESIGN-SIGNIFICANT DEFECTS.
I MINIMUM 60 ITEMS FOR POPULATIONS >200 ITEMS 2.
ENGINEERING JUDGMENT (EJ)
BASED ON PREVIOUSLY IDENTIFIED DISCREPANCIES ITEMS FROM SAFE-SHUTDOWN AND EMERGENCY CORE COOLING SYSTEMS 3.
MORE-HIGHLY-STRESSED (MHS)
INCLUDED ONLY IF STRESS A SIGNIFICANT FACTOR FOR POPULATION SIZE >1500, MINIMUM 60 INCLUDED FOR REINSPECTION FOR SEVERAL POPULATIONS <1500, EJ MAY HAVE BEEN SELECTED FROM MHS LIST (2072J)
Page 6 of 48 CONSTRUCTION CATEGORIES FOR WHICH STRESS IS A SIGNIFICANT DESIGN FACTOR STRUCTURAL STEEL CABLE PAN HANGERS HVAC DUCT HANGERS AND AUXILIARY STEEL LARGE-BORE RIGID PIPE SUPPORTS PIPING SYSTEM BENDS SMALL-BORE PIPE SUPPORTS SMALL-BORE AND INSTRUMENT PIPE / TUBE WELDS / MATERIAL LARGE-BORE PIPE WELDS / MATERIAL 9
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2068J/25 10/08/85
Page 7 of 48 l
SIZE OF THE POPULATION AND COW OSITION l
OF THE SA MLE FOR EACH CONSTRUCTICW CATEGORY l
NO. OF SAMPLES MHS POPULATION ISIS INSP-CONSTRUCTION CATEGORY ITEMS RANDOM EJ ADDED
'NYfAL ECTED*
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- 1. Concrete Placements 1,307 60 20 0
80 13 i
- 2. Structural Steel 10,785 62 61 0
123 60
- 3. Masonry Walls 611 60 10 0
70 4
- 4. Liners 915 60 15 0
75 0
- 5. Cadwelds (D) 13,868 60 30 0
90 0
- 6. Post Tensioning (D) 966 60 30 0
90 0
- 7. Conduit 2,828 61 61 0
122 0
- 8. Conduit Mangers 10,676 72 61 0
133 32
- 9. Cables 2,722 60 60 0
120 0
- 10. Cable Pans 893 60 30 0
90 0
- 11. Cable Pan Hangers 3,769 60 60 10 130 68
- 12. Elect. Equipment Install.
1,843 80 58 0
138 24
- 13. HVAC Ducts
'726 60 20 0
80 10
- 14. HVAC Equipment Install.
112 55 5
0 60 1
- 15. HVAC Duct Hangers and 602 60 10 45 115 60 Aux. Steel
! 9
- 16. HVAC Housing & Plenums 191 55 6
0 61 6
- 17. Field Fabricated Tanks 10 10 0
0 10 0
- 18. Mech. Equip. Install.
255 60 10 0
70 8
- 19. Touch-Up Galvanizing of 726 60 20 0
- 20. MSSS Equip. Installation 535 60 10 0
70 0
l
- 21. NSSS Supports 267 61 10 0
71 25
- 22. Small-Bore configuration 1,098 60 24 0
84 2
l
- 23. Large-Bore Rigid Supports 3,511 60 60 17 137 57
- 24. Large-Bore Non-Rigid 342 63 10 0
73 6
Supporta
- 25. Large-Bore configuration 354 60 10 0
70 11
- 26. Piping System Sends 2,922 60 30 10 100 12
- 27. Small-Sore Pipe supports 1,452 60 50 7
117 49
- 28. Small-Bore and Instrument 17,912 60 68 0
128 60 Pipe Tube velds / Material
- 29. Large-nore volds/ Material 8,035 60 59 14 133 60
- 30. Instr. Pipe / Tube supports 873 60 59 0
119 0
TUtALS 91,106 1,779 957 103 2,839 580 KEY: EJ Engineering Judgment (D) Documentation Review Only sets More-Highly-Stressed N/A Not Applicable
- Some of the items in the Random and EJ portions of the sample were also Itts. This column shows the sua of the tats items specifically selected and the 98tS items present in the Random and EJ portions.
(2090J)
Page 8 of 48 REINSPECTIONS AND DOCUMENTATION REVIEWS PERFORMED BY LEVEL II OR LEVEL III INSPECTORS CERTIFIED TO ANSI N45.2.6 EACH SAMPLE ITEM CHECKED FOR AS-BUILT CONDITION OF EACH CHECKLIST ATTRIBUTE REINSPECTION OBSERVATION WRITTEN WHEN INSTALLED CONDITION DIFFERED FROM REQUIREMENT DOCUMENTATION OBSERVATION WRITTEN WHEN DOCUMENTATION
+
O
~
COULDN'T BE LOCATED, WAS INCOMPLETE OR IMPROPERLY COMPLETED e
1 l
(2072J1.
Page 9 of 48 PROCESSING OF OBSERVATIONS OBSERVATIONS REVIEWED TO DETERMINE VALIDITY INVALID OBSERVATIONS DOCUMENTED AND CLOSED OUT VALID OBSERVATIONS (DISCREPANCIES) WERE EVALUdTED FOR DESIGN-SIGNIFICANCE DISCREPANCIES ALSO PROCESSED AS CECO NCR's 9
4 I
(2072J)
Page 10 of 48 CATEGORIES OF REINSPECTION DISCREPANCIES INSIGNIFICANT DISCREPANCIES WHICH HAD NEGLIGIBLE EFFECT (LESS THAN 10%
REDUCTION) ON THE ITEM'S CAPACITY AND NO EFFECT ON ITS ABILITY TO PERFORM SAFETY-RELATED DESIGN FUNCTION NOTABLE DISCREPANCIES WHICH HAD AN EFFECT (MORE THAN 10%) ON CAPACITY BUT NO EFFECT ON THE ITEM'S ABILITY TO PERFORM SAFETY-RELATED DESIGN FUNCTION O
DESIGN SIGNIFICANT DISCREPANCIES WHICH HAD AN EFFECT ON THE ITEM'S ABILITY TO PERFORM ITS SAFETY-RELATED DESIGN FUNCTION j
(2072J)
i.
Page 11 of 48 EVALUATION OF REINSPECTION DISCREPANCIES EFFECT OF DISCREPANCY ON ITEM'S CAPACITY TO PERFORM SAFETY-RELATED DESIGN FUNCTION, WAS EVALUATED DISCREPANT CONDITION WAS COMPARED WITH DESIGN MARGINS, a
TOLERANCES AND DESIGN PARAMETERS INSIGNIFICANT DISCREPANCIES REQUIRED NO FURTHER EVALUATION NOTABLE DISCREPANCIES WERE EVALUATED (INCLUDING 9
TRENDING WHERE APPROPRIATE) TO DETERMINE SIGNIFICANCE TO CONSTRUCTION QUALITY THERE WERE NO DESIGN SIGNIFICANT DISCREPANCIES (2072J)
CSR REINSPECT IUN REStA TS 1
I I
Total I
I I
I Cons t r uc t i on i Population i Total I Inspection I Dsscrepency i Insignificant i Notable i Perc ent I Cat egor y I
Saze i Reinspected I Points I
Reports I Discrepancies I Discrepancies ! Notable t
- - - - - - - - - - - - - - - - - - - - - - - - I
1
==
1 1
- 3 I
3
--- I N
ELECTRICAL I
I I
I I
I I
I W : Cable 1
2722 3 120 1 20145 1 108 1 276 i O I O.00% !
hO
- Cable Pans I
B93 I 90 1 30378 1 94 1 262 1 25 i O.08% I cN : Onnduit i
2028 1 122 1 5777 I 112 8 136 1 10 1 0.17X l m ri : Condust Hengers 1
10676 1 133 8 32918 8 139 1 213 I 86 I O.26% 8
$g I Cable Pan Hengers I
3769 8 130 8 131556 8 130 8 1804 8 447 1 0.35% 8 Electrical Equipment I
1843 8 138 I 57082 3 190 1 470 I 495 I O.87X I o en Cm I I
I I
I 1
I 1
I NA :
Subtotals I 22731 3
733 I 277856-I 773 1 2461 1
1083 I O.391 1 I
IIVAC I
I I
I I
I I
- IfvAC Ducts I
726 l
80 1 86488 l
123 8 519 8 166 I O.19% 1
- IfvAC Equipment i
112 3 60 8 22224 1 44 I 117 8 9 1 0.041 8
- Duct Hangers I
602 I 115 I 52483 l
115 8 698 1 194 i O.37E 8 IIVAC Housings I
191 1
61 1
18815 8 15 1 75 1 6 i O.051 8
- lanks I
10 I to 1 2198 3 36 3 437 i O I O.00% 8
- Nec h. Equipment i
255 1 70 8 9892 1 22 1 67 1 77 I O.78% 1
- HVAC Galvan reng I
726 I 80 3 3442 1 15 I 43 1
1 I
O.03X 1
- NSSS Equipment i
535 I 70 I 9309 8 12 1 35 i O I O.001 1
- NSSS Supports 3
267 I 73 1
6933 1 24 1 717 I O I 0.001 1 I
-- 8 I
I
- 1 I
I S shtotal s 3 3424 5 617 I 204784 1 406 1 2706 1 453 1 0.221 1 g
MECHANICAL I
I
't I
I I
I I
I SH Pipe Confaguration i
1098 8 84 1 2002 1 21 8
30 1 O I O.001 1 1P llegid Supports 1
3511 3
137 3 24043 I B2 1 176 3 22 I O.09X 1 I h Nnn-Re ge d Hangers I
342 8 73 8 14637 8 38 I 61 1
15 I O.101 i j
I t p Pa pe Coni n guration 3
354 I 70 1 13993 I 54 8 168 i O I O.00X l
- SB Pipe Bends i
2922 1 100 I 500 8 5 1 5 1 0 I O.001 8 i
I Sp Supports I
1452 1 117 8 16041 I
47 I 62 I 11 1
0.07X i l
! SH Welds I
17912 8 128 8 1533 3 6 I 6 8 0 I 0.001 5 1
8035 1 133 8 1876 1 4 1 4 I O I 0.00% !
I Instrumentation Hangers 1 873 8 119 8 17758 I 94 5 145 8 167 I O.941 8 I
I l
= I 351 1
657 l
215 1 0.231 I I
I I
I Subtotals 3 36499 8 961 I
93183 1 g
I S I F<uCl URAL I
I I
I I
I I
I
- Concrete i
1307 I 80 1 6641 1
76 1 175 1 51 8
0.77% 8 I St risc t ur al Steel I
10785 3 123 8 41607 8 159 I 473 8 46 I O.11% 3 I Nasonry Walls I
all I
70 1 51542 1 174 8 3786 3 276 I O.54% I
- Cont ainment Liner I
915 I 75 I 684 I 61 I
!!4 i O I O.00% 8 I
I I
I I
1 I
I --
I Subtotals I 13618 3 348 8 100474 1 470 I 4548 I 373 i O.37% 1 g
Totals I 76272 I 2659 3 676297 I 2000 I 10372 1 2124 1 0.31% 8 E
e
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i DENT 5 th' To %" LON G, */ +. f W I DE, 4" DEEP Page 20 of 48 CSR RESULTS REINSPECTION 2,659 ITEMS OVER 28 DIFFERENT CONSTRUCTION CATEGORIES WERE REINSPECTED, INVOLVING A TOTAL OF 365 DIFFERENT ATTRIBUTES.
THESE INSPECTIONS INVOLVED OVER 650,000 INSPECTION POINTS.
THERE WERF NO DESIGN SIGNIFICANT DISCREPANCIES IN THE SAMPLE REINSPECTED.
9 THE TOTAL NUMBER OF DISCREPANCIES WAS LESS THAN 2%,
MORE THAN 75% OF THESE WERE INSIGNIFICANT AND DID NOT AFFECT THE ITEMS CAPABILITY TO PERFORM ITS INTENDED SAFETY FUNCTION.
IN EACH OF THE CONSTRUCTION CATEGORIES, NOTABLE DISCREPANCIES AMOUNTED TO LESS THAN ONE PERCENT.
ALTHOUGH CAPACITY WAS REDUCED, THESE DISCREPANCIES DID 4
NOT AFFECT THE CAPABILITY OF THE ITEM TO PERFORM ITS INTENDED SAFETY FUNCTION.
l 2067J 10/03/85 Page 21 of 48 4
CSR RFSUL TS (CONT'D) i ALTHOUGH NO DCSIGN SIGNIFICANT DISCREPANCIES WERE IDENTIFIED FOR ANY CONSTRUCTION CATEGORY, NOTABLE DISCREPANCIES WERE FURTHER EVALUATED TO FULFILL THE BCAP COMMITMENT TO IDENTIFY POSSIBLE "SIGNIFICANT CONDITIONS ADVERSE TO QUALITY."
BCAP RECOMMENDS THAT WITH RESPECT TO 5 CONSTRUCTION ATTRIBUTES (0UT OF 365), FOLLOWUP ACTION TO FURTHER ENHANCE CONFIDENCE IS APPROPRIATE.
THESE ATTRIBUTES ARE:
9 1.
MORTAR FILL FOR INTERIOR MASONRY WALL COLUMNS 2.
RUNNING BOND AT MASONRY WALL INTERSECTION 3.
CONDUIT ATTACHMENT TO HANGERS 4.
STIFFENERS FOR ELEC. EQUIPMENT 5.
2067J 10/03/85
Page 22 of 48 CSR RESulTS (CONT'D)
DOCUMENTATION rey 1EM 2,736 ITEMS OVER 30 DIFFERENT CATEGORIES WERE REVIEWED
+
FOR QUALITY DOCUMENTATION AND WERE EVALUATED TO DETERMINE SIGNIFICANCE TO QUALITY OF CONSTRUCTION.
THIS INVOLVED TENS OF THOUSANDS OF DOCUMENTS AND OVER HUNDRED THOUSAND PIECES OF INFORMATION.
GENERALLY, COMPLETE AND ACCURATE DOCUMENTATION EXIST TO SUPPORT QUALITY OF CONSTRUCTION.
9 MOST OF THE DISCREPANCIES WERE INSIGNIFICANT, NONE POINTED TO DESIGN SIGNIFICANT HARDWARE DISCREPANCIES IN THE S' AMPLE.
TWO REQUIRE FURTHER EVALUATION.
1.
GROUTING FOR BASE PLATE, AND PATCHES 2.
HVAC WELDER QUALIFICATION 2067J 10/03/85 Page 23 of 48 CSR CONCLUSIONS THERE IS HIGH CONFIDENCE THAT THE CONSTRUCTION AT BRAIDWOOD MEETS THE DESIGN REQUIREMENTS AND THEREFORE THE CONSTRUCTION AT BRAIDWOOD IS OF ACCEPTABLE QUALITY.
THE QUALITY DOCUMENTATION IS SUFFICIENTLY COMPLETE AND ACCURATE TO SUPPORT THE QUALITY OF CONSTRUCTION.
CONFIDENCE WITH RESPECT TO 5 CONSTRUCTION ATTRIBUTES AND 2 DOCUMENTATION DEFICIENCIES IDENTIFIED PREVIOUSLY CAN BE ENHANCED WHEN BCAP RECOMMENDATIONS ARE ADDRESSED.
2067J 10/03/85 Page 24 of 48 REVIEW OF PROCEDURFS TO SPECIFICATION RFQUIREMENTS (RPSR)
OBJECTIVES METHODOLOGY RESULTS CONCLUSIONS 9
2048J/1 10/09/85
1 Page 25 of 48 RPSR - REVIEW OF PROCEDURES TO SPECIFICATION REQUIREMENTS OBJECTIVE:
TO ASSURE THAT ON-SITE CONTRACTORS' PROCEDURES GOVERNING ON-GOING AND FUTURE SAFETY-RELATED CONSTRUCTION AND INSPECTION ACTIVITIES ADDRESS ALL APPLICABLE DESIGN AND REGULATORY REQUIREMENTS.-
9
{
2048J/2 10/09/85 Page 26 of 48 RPSR ACTIVITIES DETERMINE DESIGN AND REGULATORY REQUIREMENTS REVIEW SPECIFICATIONS REVIEW FSAR IDENTIFY APPLICABLE CONTRACTOR PROCEDURES
+
ONG0ING AND FUTURE SAFETY RELATED CONSTRUCTION AS OF JUNE 30, 1984 COMPARE DESIGN AND REGULATORY REQUIREMENTS TO PROCEDURAL CONTENT IDENTIFY DIFFERENCES (0BSERVATIONS)
DOCUMENT AND EVALUATE OBSERVATIONS DETERMINE IF OBSERVATION IS A CONCERN CONCERNS PROCESSED AS CECO NCR'S OBSERVATIONS WHICH WERE NOT VALID CONCERNS, DOCUMENTED / CLOSED OUT 1
2048J/3 10/09/85
Page 27 of 48 RPSR RESULTS NUMBER NUMBER OF OF NUMBER OF DIFFERENCES S&L PROCEDURES REQUIREMENTS NOTED FOR CONCERNS CONTRACTOR SPEC.
REVIEWED IDENTIFIED EVALUATION IDENTIFIED L.K. Coastock and L-2790 109 642 92 0
Company Inc.
Nuclear Installation L-2834 37 467 36 0
Services Company G.K. Newberg L-2722 43 564 105 1
Construction Company Pittsburgh Testing L-2850 44 722 133 1
Laboratory 9
Phillips, Getschow L-2739 130 759 123 0
Company Pullman Sheet Metal L-2782 58 344 67 0
Works, Inc.
o Midway Industrial L-2831 39 275 52 0
Contractors, Inc.
Chicago Bridge and L-2725 131 418 40 1
Iron Works M & O Insulation L-2828 1*
3 2
0 Company TOTAL 592 4,194 650 3
- M&O utilized the specification as the procedure.
(2049J)
Page 28 of 48 RPSR RESULTS SIX CONTRACTORS - NO CONCERNS IDENTIFIED GUST K. NEWBERG CONSTRUCTION COMPANY TWO REQUIREMENTS NOT ADDRESSED PERTAINING TO WELDING SEQUENCE AND DISTORTION CONTROL PITTSBURGH TESTING LABORATORY ONE REQUIREMENT NOT ADDRESSED PERTAINING TO CONCRETE EXPANSION ANCHOR WORK INSPECTION 9
CHICAGO BRIDGE AND IRON COMPANY
~
ONE REQUIREMENT NOT ADDRESSED PERTAINING TO PENETRANT NONDESTRUCTIVE EXAMINATION 2048J/24 10/09/85
Page 29 of 48 GUST K. NFWBFRG CONSTRUCTION COMPANY e
REQUIREMENTS FOR WELDING SEQUENCE TO CONTROL DISTORTION AND SHRINKAGE NOT ADDRESSED REQUIREMENTS DO NOT POSE A PROBLEM SINCE:
+
USE OF GKN QUALIFIED WELDING PROCEDURES GKN QC VERIFICATION OF WELDS PTL VISUAL INSPECTION OF WELDS NO EFFECT ON INSTALLATION QUALITY
+
9 l
2048J/25 10/09/85
Page 30 of 48 PITTSBURGH TESTING LABORATORY EMBEDMENT DEPTH DIMENSION INSPECTION REQUIREMENT FOR CEA'S INSTALLED IN SURFACED REPAIRED CONCRETE NOT ADDRESSED PTL PROCEDURE REVISED AUGUST 14, 198S INCORPORATING
+
+
DISPOSITION OF CONCERN DOCUMENT REVIEW REINSPECTION OF ANY ANCHORS IN REPAIRED CONCRETE NCR DEFICIENCY TRACKING DOCUMENT FOR CECO UNTIL RESOLUTION NO EFFECT ON PAST CONSTRUCTION EXPECTED BECAUSE INSTALLA-TION CONTRACTOR'S PROCEDURES ADDRESSED REQUIREMENT I
2048J/12 10/09/8S Page 31 of 48 CHICAGO BRIDGE AND IRON COMPANY REQUIREMENT NOT SPECIFICALLY ADDRESS FOR PENETRANT TEST OF AT LEAST 1/2 INCH OF THE ADJACENT BASE METAL CONCERN DOES NOT POSE A PROBLEM SINCE:
CB&I REQUIRES WELD TO BE EXAMINED AND ALL ADJACENT AREAS WITHIN AT LEAST ONE INCH TO BE PREPARED AND CLEANED APPLICATION OF PENETRANT MATERIAL EXPOSES MORE AREA FOR EXAMINATION THAN REQUIRED CB&I PERFORMED ONLY A SMALL NUMBER OF PENETRANT TESTS CECO QA SURVEILLANCE MAY 1985 SHOWED CB&I PROPERLY PERFORMING PENETRANT TESTS NO EFFECT ON PAST CONSTRUCTION 2048J/27 10/09/85 Page 32 of 48 RPSR CONCLUSIONS PROCEDURES ADEQUATELY ADDRESS THE REQUIREMENTS CONTAINED IN THE SPECIFICATIONS AND THE FSAR VALID CONCERNS HAD NO OBSERVED EFFECT ON THE QUALITY OF COMPLETED SAFETY-RELATED CONSTRUCTION WORK PROPER IMPLEMENTATION OF PROCEDURES WILL ASSURE QUALITY OF ON-GOING AND FUTURE CONSTRUCTION 0
i I
2048J/28 10/09/85 Page 33 of 48 REVIEW OF SIGNIFICANT CORRFCTIVE ACTION PROGRAMS (RSCAP)
OBJECTIVE METHODOLOGY 4
RESULTS CONCLUSIONS 9
l 2070J 10/04/85
Page 34 of 48 REVIEW 0F SIGNIFICANT CORRECTIVE ACTION PROGRAMS (RSCAP)
OBJECTIVE:
TO DETERMINE THAT "WHERE PAST CONSTRUCTION PROBLEMS HAVE BEEN IDENTIFIED WHICH RESULTED IN SIGNIFICANT CORRECTIVE ACTIONS, SUCH CORRECTIVE ACTIONS HAVE BEEN ADEQUATELY IMPLEMENTED AND DOCUMENTED.
9 2070J 10/04/85
Page 35 of 48 RSCAP METHODOLOGY i
)
RSCAP EFFORT CONSISTS OF THE FOLLOWING REVIEW STEPS FOR EACH SCAP:
- COMMITMENT REVIEW A REVIEW AND LISTING OF VARIOUS BRAIDWOOD DOCUMENTS REQUIRING THE CORRECTIVE ACTION SUCH AS: 50.55(E),
NRC INSPECTION REPORTS, AUDITS, AND NCR'S.
- PROCEDURE REVIEW A REVIEW OF THE PROCEDURES GOVERNING THE CORRECTIVE ACTION PROGRAM FOR i
j ADEQUATE INCORPORATION OF THE PROGRAM COMMITMENT (S).
9
- IMPLEMENTATION REVIEW A REVIEW OF THE IMPLEMENTATION OF THE l
REQUIREMENTS OF THE GOVERNING j
PRUCEDURES (FOR ONGOING SCAP'S).
l
- DOCUMENTATION REVIEW A REVIEW 0F THE DOCUMENTATION GENERATED DURING THE IMPLEMENTATION PHASE OF THE f
CORRECTIVE ACTION PROGRAM.
THIS EFFORT WILL ENSURE THE VALIDITY OF THE CONCLUSIONS REACHED IN j
RELATION TO THE RESPECTIVE PROGRAM OBJECTIVES.
I (1029J) 10/09/85
Page 36 of 48 9
RSCAP PROGRAMS RFVIEWFD REINSPECTION OF SAFETY-RELATED MECHANICAL EQUIPMENT
+
QUALITY CONTROL INSPECTOR REINSPECTION PIPING HEAT NUMBER TRACEABILITY VERIFICATION QC STRUCTURAL STEEL REVIEW ELECTRICAL INSTALLATION DOCUMENT REVIEW 9
SAFETY-RELATED PIPE SUPPORTS HVAC RETROFIT PROGRAM INSTRUMENTATION INSTALLATION VERIFICATION
=
NSSS COMPONENT SUPPORTS 2070J 10/04/85
Page 37 of 48 m
PIPING HEAT NUMBER TRACEABILITY VERIFICATION PROGRAM BACKGROUND 4
THIS PROGRAM WAS ESTABLISHED TO VERIFY THAT ALL LARGE AND SMALL BORE PIPING MATERIALS INSTALLED BY PHILLIPS, GETSCHOW COMPANY PRIOR TO 11/82 AND 7/83, RESPECTIVELY, WERE CORRECT AND TRACEABLE.
RSCAP RESULTS PROCEDURES FOR IMPLEMENTING THE PROGRAM WERE ADEQUATE.
REVIEW IDENTIFIED TWO OBSERVATIONS.
BOTH OBSERVATIONS PERTAINED TO LACK OF WRITTEN INSTRUCTIONS FOR CERTAIN 9
ASPECTS OF WORK BEING DONE.
THE WORK WAS BEING PERFORMED I
PROPERLY, THE PROCEDURE WAS LATER UPGRADED TO ELIMINATE THESE DEFICIENCIES, PROCEDURES WERE ADEQUATELY IMPLEMENTED.
REVIEW IDENTIFIED TWO OBSERVATIONS.
ONE PERTAINED TO EXCLUSION OF CERTAIN i
IS0 METRICS FROM THE PROGRAM.
THE OTHER PERTAINED TO NOT l
STRICTLY FOLLOWING PROCEDURAL REQUIREMENTS.
THESE l
OBSERVATIONS WERE CORRECTED AND DID NOT SIGNIFICANTLY AFFECT i
THE OVERALL EFFECTIVENESS OF THE PROGRAM.
i l
DOCUMENTATION WAS FOUND TO BE ADEQUATE.
i l
OVERALL ASSESSMENT THE PROGRAM WAS EFFECTIVELY IMPLEMENTED AND DOCUMENTED.
1030J 10/09/85
. _ _ _. _ _ _ _ _ _ _ _ ~. _., _ _ _ _ _ - _ -, - _,
I*
Page 38 of 48 4
I SAFETY-RELATED PIPE SUPPORTS BACKGROUND 3
l PHILLIPS, GETSCHOW CO. (PGCO) CONDUCTED A PROGRAM TO REINSPECT l
SAFETY-RELATED PIPE SUPPORTS INSTALLED PRIOR TO SEPTEMBER 1982.
RSCAP RESULTS PROCEDURE WAS ADEQUATE THERE WERE NO OBSERVATIONS.
IMPLEMENTATION WAS EFFECTIVE.
THERE WERE TWO OBSERVATIONS PERTAINING TO NOT STRICTLY FOLLOWING PROCEDURAL REQUIRE-MENTS.
HOWEVER, THESE HAD NO EFFECT ON OVERALL EFFECTIVE-i NESS OF THE PROGRAM.
9 DOCUMENTATION REVIEW SHOWED ONE OBSERVATION PERTAINING TO NOT STRICTLY FOLLOWING DOCUMENTATION REQUIREMENTS.
THIS TYPE OF DEFICIENCY CAN BE EXPECTED TO BE CORRECTED DURING j
THE C NTRACTORS FINAL DOCUMENT REVIEW.
i OVERALL RSCAP ASSESSMENT THE PROGRAM HAS BEEN EFFECTIVELY IMPLEMENTED.
FINAL DOCUMENTATION REVIEW BY THE CONTRACTOR WILL ASSURE THAT ANY DOCUMENTATION DEFICIENCIES ARE ELIMINATED.
i (1029J) 10/09/85 Page 39 of 48 QUALITY CONTROL STRUCTURAL STEEL REVIEW BACKGROUND THE QCSSR WAS A COMMONWEALTH EDISON INITIATED PROGRAM TO COLLECT
~
l INFORMATION ON QUALITY OF CONSTRUCTION OF STRUCTURAL STEEL AND REPORT DATA TO THE ARCHITECT ENGINEERS FOR THEIR ANALYSIS.
THE PROGRAM WAS PERFORMED BY G.K. NEWBERG, INC.
RSCAP RESULTS PROCEDURE FOR IMPLEMENTATION WAS ADEQUATE.
IMPLEMENTATION OF THE PROCEDURE WAS ADEQUATE EXCEPT FOR A MINOR 9
OBSERVATION - (WELD MEASURING TOOLS)
DOCUMENTATION WAS ADEQUATE EXCEPT FOR A MINOR OBSERVATION INVOLVING A PROCEDURE FORM NOT ALWAYS BEING USED.
THIS HAD N0 i
EFFECT ON THE OVERALL EFFECTIVENESS OF THE PROGRAM.
OVERAll RSCAP ASSESSMFNT PROGRAM WAS EFFECTIVELY IMPLEMENTED AND DOCUMENTED.
l 1030J 10/09/85 Page 40 of 48 INSTRUMENTATION INSTALLATION VERIFICATION BACKGROUND PHILLIPS, GETSCHOW CO. (PGCO) CONDUCTED A PROGRAM TO REINSPECT INSTALLATION OF INSTRUMENTATION AND TO REVIEW ASSOCIATED DOCUMENTATION FOR WORK PERFORMED PRIOR TO FEBRUARY 1984.
RSCAP RESULTS PROCEDURE WAS ADEQUATE.
PROCEDURES WERE ADEQUATELY IMPLEMENTED.
THERE WAS ONE OBSERVATION PERTAINING TO THE LACK OF INCORPORATION OF A FIELD CHANGE REQUEST.
THIS HAD NO EFFECT ON THE OVERALL EFFECTIVENESS OF THE PROGRAM.
O DOCUMENTATION WAS FOUND TO BE ADEQUATE.
OVERALL RSCAP ASSESSMENT THE PROGRAM WAS EFFECTIVELY IMPLEMENTED AND DOCUMENTED.
(1029J) 10/09/85
Page 41 of 48 HVAC RETROFIT PROGRAM BACKGROUND THE HVAC RETROFIT PROGRAM WAS DESIGNED TO CORRECT PROBLEMS ASSOCIATED WITH OMITTED WELDS, IMPROPER CONFIGURATION, AND LACK OF APPROVED DETAILS FOR DUCT ACCESSORY FABRICATION.
RSCAP RESULTS
- IMPLEMENTING PROCEDURES WERE ADEQUATE.
- IMPLEMENTATION WAS ADEQUATE.
- DOCUMENTATION WAS ADEQUATE.
OVERALL RSCAP ASSESSMENT PROGRAM'WAS EFFECTIVELY IMPLEMENTED AND DOCUMENTED.
1 i
l' (1029J) 10/09/85
Page 42 of 48 NSSS COMPONENT SUPPORT VERIFICATION PROGRAM BACKGROUND THIS PROGRAM WAS ESTABLISHED TO ACCOMPLISH VERIFICATION AND INSTALLATION ACTIVITIES REQUIRED FOR COMPLETION AND ISSUANCE OF AN N-5 FOR THE NSSS SUPPORTS.
RSCAP RESULTS l
THE PROVISIONS AND SCOPE OF THE PROGRAM ARE CURRENTLY
)
ADEQUATELY DEFINED AND ESTABLISHED.
I INITIAL RSCAP REVIEW SHO.l?D THAT EXISTING DOCUMENTATION WAS DEFICIENT.
FOLLOW-UP REVIEW INDICATES THAT APPROPRIATE CONTROL MEASURES HAVE BEEN OR ARE BEING ESTABLISHED TO ASSURE CORRECTION OF DOCUMENTATION DEFICIENCIES.
COMPLETION OF THE COMPREHENSIVE FINAL DOCUMENT REVIEW ASSURES THAT THE PROGRAM COMMITMENTS WILL BE MET AND ISSUANCE OF ASME N-5 REPORTS WILL BE COMPLETED.
OVERALL RSCAP ASSESSMENT PROGRAM WHEN COMPLETED IS EXPECTED TO BE EFFECTIVE.
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(1029J) 10/09/85 Page 43 of 48 QC INSPECTION REINSPECTION PROGRAM BACKGROUND THE OBJECT OF THE PROGRAM IS TO CONFIRM THROUGH REINSPECTIONS, THE EFFECTIVENESS OF CONTRACTOR QC INSPECTOR CERTIFICATION PROGRAMS FOR THE PERIOD PRIOR TO THE REVISION OF THE CONTRACTOR PROCEDURES IN LATE 1982.
RSCAP RESULTS
- THE OBJECTIVE AND SCOPE OF THE PROGRAM ARE CLEARLY DEFINED AND DOCUMENTED.
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- THE GOVERNING AND SUPPORTING PROCEDURES AND WORK INSTRUCTIONS FOR THE PROGRAM ARE SUFFICIENT TO FULFILL THE OBJECTIVES.
OVERALL RSCAP ASSESSMFNT THE PROGRAM, WHEN COMPLETED, IS EXPECTED TO BE EFFECTIVE.
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1030J 10/09/85 Page 44 of 48 REINSPECTION OF SAFETY RELATED MECHANICAL EQUIPMENT BACKGROUND THE SUBJECT PROGRAM CONSISTS OF TWO MAJOR ACTIVITIES.
1.
MECHANICAL EQUIPMENT INSTALLATION STATUS PROGRAM 2.
STEAM GENERATOR BOLTING REINSTALLATION PROGRAM RSCAP RESULTS PROCEDURES AND INSTRUCTIONS WERE SUFFICIENT TO ENSURE O
FULFILLMENT OF THE PROGRAM COMMITMENTS.
- INSTALLATION STATUS OF EQUIPMENT WAS INITIALLY ESTABLISHED EQUIPMENT'TO BE INCLUDED IN THE PROGRAM WAS ACCURATELY i
IDENTIFIED 1033J 10/09/85 1
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Page 45 of 48 REINSPECTION OF SAFETY RELATED MECHANICAL EQUIPMENT (CONT'D) i RSCAP RESULTS (CONT'D) l CONTRACTOR AND CECO INSPECTION REVIEWS, PLACEMENT OF l
HOLD POINTS AND MONITORING OF WORK ACTIVITIES WERE IN l
ACCORDANCE WITH PROCEDURE REQUIREMENTS AT THE TIME OF INITIAL BCAP REVIEW THE CONTRACTOR HAD RECOGNIZED THE NEED FOR UPGRADING THEIR DOCUMENTATION PACKAGES.
BCAP OBSERVATIONS WERE ADDRESSED BY THE CONTRACTOR AS PART OF THIS UPGRADING.
FOLLOW-ON REVIEW BY BCAP SHOWS RECONSTRUCTION OF 9
DOCUMENTATION PACKAGES IS RESULTING IN SATISFACTORY DOCUMENTATION.
ACTIONS TAKEN BY THE CONTRACTOR HAVE BEEN EFFECTIVE IN ESTABLISHING TRACEABILITY OF SG BOLT MATERIAL i
S.G. BOLT / HELI-COIL REMOVAL AND REPLACEMENT DOCUMENTA-l TION WAS CLEAR AND VERIFIABLE i
OVERALL ASSESSMENT l
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I 1033J 10/09/85
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Page 46 of 48 i
ELECTRICAL INSTALLATION DOCUMENT REVIEW PROGRAM BACKGROUND THIS PROGRAM CONSISTS OF A REVIEW OF L.K. COMSTOCK RECORDS FOR i
RETRIEVABILITY, ACCOUNTABILITY AND PROCEDURAL COMPLIANCE RSCAP RFSULTS RECORDS RETRIEVABILITY SYSTEM WAS ESTABLISHED AND PROPERLY IMPLEMENTED.
l PROCEDURES WERE GENERALLY ADEQUATE.
l9 INADEQUATE PROCEDURE IMPLEMENTATION RESULTED IN A LESS THAN l
THOROUGH CONTRACTOR REVIEW OF THE RECORDS.
j THE PROGRAM WAS UPGRADED ON CECO AND CONTRACTOR INITIATIVE.
A FOLLOW-ON REVIEW BY BCAP SHOWED THAT THE PROCEDURE WAS BEING EFFECTIVELY IMPLEMENTED.
l OVERALL RSCAP ASSESSMENT THE PROGRAM IS BEING EFFECTIVELY IMPLEMENTED AND DOCUMENTED.
I 1030J 10/09/85 i
Page 47 of 48 RSCAP CONCLUSIONS l
1 THE FOLLOWING SCAPS HAD BEEN/WERE BEING EFFECTIVELY IMPLEMENTED 4
AND DOCUMENTED.
PIPING HEAT NUMBER TRACEABILITY SAFETY RELATED PIPE SUPPORTS QUALITY CONTROL STRUCTURAL STEEL REVIEW INSTRUMENTATION INSTALLATION VERIFICATION HVAC RETROFIT THE FOLLOWING SCAPS WERE IN THE PROCESS OF BEING UPGRADED AT THE TIM!! 0F RSCAP REVIEW 9
t j
NSSS COMPONENT SUPPORT VERIFICATION QC INSPECTOR REINSPECTION PROGRAM REINSPECTION OF SAFETY RELATED MECHANICAL EQUIPMENT ELECTRICAL INSTALLATION DOC REVIEW 1
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ALTHOUGH SOME DEFICIENCIES WERE NOTED'DURING INITIAL RSCAP REVIEW, MANY OF THESE DEFICIENCIES HAD BEEN RECOGNIZED BY THE CONTRACTOR / CECO PRIOR TO BCAP REVIEW A FOLLOW-ON REVIEW BY BCAP INDICATES THAT AS A RESULT OF THE UPGRADING, THE PROGRAMS WILL BE EFFECTIVE i
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Page 48 of 48 o
BCAP SUMARY CONCLUSIONS THERE IS HIGH CONFIDENCE THAT THE CONSTRUCTION AT BRAIDWOOD MEETS THE DESIGN REQUIREMENTS AND THEREFORE THE CONSTRUC-TION IS OF ACCEPTABLE QUALITY.
A FEW FOLLO'w-UP ACTIONS WILL FURTHER ENHANCE THE CONFIDENCE IN CONSTRUCTION.
THE PROCEDURES FOR ON-GOING AND FUTURE SAFETY-RELATED CONSTRUCTION ADEQUATELY ADDRESS THE DESIGN AND REGULATORY REQUIREMENTS.
THUS THE ONGOING AND FUTURE CONSTRUCTION AT BRAIDWOOD CAN BE EXPECTED TO BE OF ACCEPTABLE QUALITY.
THE SIGNIFICANT CORRECTIVE ACTIONS WERE OR WILL BE EFFECTIVE.
9 (2088J)