ML20214A696

Intervenor Exhibit I-ROREM-154,consisting of 850402 Memo Forwarding Bcap Memo 968 Re AIR-009,clarification of Addl Info

ML20214A696
Person / Time
Site:	Braidwood
Issue date:	10/06/1986
From:	Smith N COMMONWEALTH EDISON CO.
To:	Kaushal N COMMONWEALTH EDISON CO.
References
OL-I-ROREM-154, NUDOCS 8705190554
Download: ML20214A696 (23)

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. 7 un, j mj p, .f ; April 2. 1985 d ou BRD #15.459 i TO: N. N. Kaushal BCAP Director

SUBJECT:

AIR #009 BCAP Q.A. accepts your explanations and clarifications of the issues brought forth in AIR #009 and it is closed. N. P. Smith General Supervisor Q.A. Braidwood Station NPS/WJM/nlw (0350B) cc: E. E. Fitzpatrick Q. A. File - 71.7 71.12 (#009) nJ;tta 2C litC0gy coaufss;04 , y R.{lV{e el VC$ Cf*ic'ai inh. N1 "l' ~ Q q j n. w ds 1,-{$$$0Nb i u ,,.a t o >I w m-ms cat't CWu ,gg _yQ nl W l ~~ cent - B. C. A. P. com Reportet / W/ j 0705190554 861006 PDR ADOCK 0500 6 ' '] 7 ]N191&dd(Ok$_ M exmaii/ W n:'q b) W __s.nati: unctian sir.23

March 2$. 1985 BCAP Memo 8%8 10: N. P. Smith FROM: G. M. Orlov

SUBJECT:

AIR-009, Clarification of Additional Information l

REFERENCES:

a) QA Memo BRD 815.262 dated March 19, 1985 b) BCAP Memo 4800 Dated March 5. 1985 The following additional information is provided in response to the Reference (a) memo. 1. Definitions of terms used in Reference (b): Generic Design Requirements - Requirements regarding construction A. that apply to more than one item. Examples of such requirements may be those in NRC codes, Architect / Engineer specifications, general drawings not specific to any one item and specific parts of codes or standards that apply to a class of items. Item-specific Design Requirements - Those requirements invoked B. regarding the construction of one particular ites. These include a specific design drawing for a component and all referenced codes, standards, specifications, general drawings, etc. invoked by that drawing. Item-specific Acceptance criteria - These are the reinspection or C. documentation review checklist acceptance criteria in a package for a specific sample ites. They are developed from design requirements, but may be less stringent when it has been - determined that the design will allow a relaxation in the construction tolerances. Specification Requirements - Those requirements defined in an D. Architect / Engineer document labeled a " Specification". E. Specification - An Architect / Engineer doctament labeled as a " specification" 2. Meaning of the following quote in terms of writing observations: "If the design requirements have become more stringent subsequent to an item's installation, provisions within BCAP allow for the invalidation of observations that result from application of the more stringent requirements (BCAP Prog. Doc. at II-2 and BCAP-06, l para. 4.3.3c). i 1097J

.. Neil Smith March 25. 1985 SCAP does not plcn to writo ob:Grvctions in the instance where design-requirements have become more stringent subsequent to an item's installation since this is not within BCAP scope. CBCo at Braidwood is expected have other QA programs that are designed to ensure that any more stringent requirements are recognized and that previously completed work is reviewed to determine the possible need for rework. BCAP does not include such provision within its scope, rather ensuring that at least a " snapshot in time

• view of the construction design-significant quality is taken.

This approach recognizes that less stringent requirements indicate 'the lack of design-significance of those previous requirements. Therefore, where less stringent requirements are known to BCAP. such i changes are acknowledged by invalidating observations written regarding a failure to meet the old requirements. i 3. Second sentence of Section 3-A. regarding the development of acceptance criteria in most cases, from latest design requirements: Acceptance criteria are, for checklist preparation, developed based first on consideration of the latest design requirements. however (as explained in the third and fourth sentences of Section 3.A.) alternate criteria may be used if less stringent, but still design-significant criteria, can be developed. The words "in most cases" were intended to convey that the final acceptance criteria as used in the checklist may not end up identical to those in the latest drawings and specification requirements. 4. Third sentence of Section 3.A regarding relaxation of design-requirements when an attribute is already deemed design-significant: In the case where an attribute is design-significant. Its design-requirements are then examined to determine acceptance criteria for BCAP use as explained in item 3 above. The subject sentence in Reference (b) is correct as written in that BCAP inspection criteria may be less stringent than original inspection criteria, as discussed in (I c. above) yet BCAP results will properly indicate design-significant deviations should they exist. ( hk y.M.orlov Assistant BCAP Director cc: BCAP File QG.69.60.3 QG.69.60.2.6 90.69.80.2 / N. Kaushal L. Weiss P. 14u 1097J

March 19. 1985 BRD #15.262 To: N. N. Kaushal G. M. Orlov PROM: N. P. Smith

SUBJECT:

Clarification of Additional Information Regarding AI

REFERENCE:

1. AIR-09 dated Febr.uary 1, 1985 2. BCAP Response dat'ed February 21 1985 3. BRD #14.982 dated February 21 1985 4. BCAP Memo N800 dated March 5. 1985 In our review of the additional information that BCAP has provided (dated 3-5-85), we feel that additional information is needed. We would like you to define several terms used in BCAP Memo #800 (dated 3-5-85). The terms used which we feel need to be defined are as follows: A. Generic Design Requirements .it B. Item - Specific Design Requirements C. Item - Specific Acceptance Criteria D. Specification Requirements E. Specification What is meant by. "If the design requirementG have become more stringent but meet the original requirementc (BCAP Prag. Doc. at II-2 and BCAP-06, para. 4.3.3c).", in terms of writing observations (i.e. generic or specific observations). fk (03208) Y MAH 21 RECD \\ 1100111'.) a u v 8.C.A.P. ~ w

9 BRD #15.262 Page 2 Also in DCAP Memo #000 cection 3.A second sentence it states "in most cases", why not in all pases? And in the third sentence of section 3.A. how can the crPteria be relaxed from design requirements from a design - significance standpoint when the attribute has already been deemed design - significant, i Please provide the above information by March 22. 1905. 4 h N. P. Smith General Supervisor Quality Assurance NPS/ PAL /nlw (0320B) cc: E. E. Fitzpatrick i P. A. Lau Q. A. File - 71.7 71.12 .u a 'I 110011123 4 1 ..===*% I

March 11, 1985 BRD 015,155 TO: M. N. Kaushal' G. M. Orlov FROM: N. P. Smith

SUBJECT:

Clarification of Additional Information Regarding AIR-09

REFERENCE:

1. AIR-009 dated February 1, 1985 i 2. BCAP Response dated February 21, 1985 3. BRD 014,982 dated February 21, 1985 4. BCAP Memo #800 dated March 5. 1985 In our review of the additional information that BCAP has provided (dated 3-5-85), we feel that additional clarification is i needed. Therefore, we are presenting a few examples, as we interpret the additional information, for your review and approval. Example 01: A particular population has had several revisions to the field installation (contractor specifications and/or drawings) tolerances which were more restrictive for each revision. Issue Date Length Tolerance . u-A. Original issue (3-2-78) z 4" B. Rev. A (3'-14-79) z 3" C. Rev. B (6-9-82) 1 2" D. Rev. C (10-6-83) z 1" t E. Rev. D (11-7-84) z 1/2" In this example a generic observation would be written for all population 1tems not meeting the Rev. D (11-7-84) tolerances, that is those population items constructed to the Original issue up to and including Rev. C (10-6-83) would be covered by the generic observation. i 33@$3M$

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i100111'ai MAH 11 RECD (0298B) 3 B.C.A.P.

BRD #15,155 Page 2 Example #2: A particular population has had several revisions to the field i installation (contractor specifications and/or drawings) tolerances which were less rostrictive for each revision. Issue Date Length Tolerance A. Original issue (3-2-78) t 1/2" B. Rev. A (3-14-79) i 1" C. Rev. B (6-9-82) a 2" D. Rev. C (10-6-83) i 3" l E. Rev. D (11-7-84) t 4" In this example no generic observations would be written. I Example 03: A particular population has had a requirement deleted from the I l contractor specification or a design drawing: Issue Date Requirement A. Original issue (3-2-78) floor to be painted purple l B. Rev. A (3-14-79) floor to be painted any color C. Rev. B (12-13-84) - floor does not have to be painted In this example no observations of any kind would be written on painting associated with floors. Example 04: A particular population included a population item where the design was changed since the installation of the item but tho item had not been reworked. A. Original construction (dated 5-3-82) dimension. 3" x 3" x 14" tube stool. i D. Rodosign as por revised drawing (dated 12-4-04) dimension. 3" x 3" x 18" tubo stool. i It00111'J7 (02980)

3 BRD #15,155 Page 3 2 In this example an observation would be written. then during evaluation it was found to be constructed as per original design. the observation would be evaluated as an invalid observation. Example 05: 1 A.particular population included a population item where the i design was changed after installation of the item and then was { reworked after 6-30-84. A. Original construction.(dated 5-3-82) dimensibn, 3" x 3" x 14" tube steel. i B. Redesign as per revised drawing (dated 7-4-84) dimension. 3 x 3" x 18" tube steel. C. Item reworked on 0-3-84 to meet new redesign. In this example the population item would be deleted and replaced as an invalid samplo item. 1 Also, we would like to clarify tho following terms: .l A. Generic Design Requirements are those documents which i provide a contractor with general guidance in terms of general construction activities which may include the following documents: i 1. Contractor Specifications 2. Design Drawings 3. Codes i 4. Standards j 5. Contractor procedures 6. Other generic (type) documents B. Item - Specific Design Requirements are those documents i which provide a contractor with specific guidance in terms o* construction of a specific population item which may include the following documents: 1 1. Detailed Design Drawings l 2. A cpecific paragraph or sub-patagraph of a specific code i (02988) IIOU111'Ub - - ~ - - ~ - - - - - - ~ - - - - ~ ~ ~ ~ - ~~

BRD #15.155 Pago 4 3. A specific paragraph or sub-paragraph of a specific l standard 4. A specific requirement from a contractor procedure I Please provide your concurrence to the above examples by approving this document i below by March 15, 1985. k ML) {! N. P. Smith i i General Supervisor Quality Assurance e 1 i Reviewed by: i i G. M. Orlov l Assistant Director BCAP 3 i l i L j Approved by: i N. N. Kaushal i i BCAP Director NPS/ PAL /n1w (02988) j cc: E. E. Fitzpatrick i P. A. Lau i, Q. A. File - 71.12 l 71.7 I i I, ,1 ) i 1 i 1100111'.'9 )

i + ] March 5, 1985* j BCAP Meno 0800 l i i l i t TO: N. P. Smith I l ] FROM: G. M. Orlov l \\ j

SUBJECT:

Additional Information Regarding AIR-009 1 i REFERENCE 4 BRD #14,982 dated February 25, 1985 i j .i i \\ The attached provides information you requested in the { reference regarding the basis for the CSR clement using I design requirements applicable after June 30, 1984, to j review construction work completed as of that date. l Your consideration of the closure of AIR-009 based on this additional information will be appreciated. ) l i ~ G M. Orlov j Assistant BCAP Director i ? j GMO/LSW/sjs i Attachment cc N. N. Kaushal f i BCAP File QG 69.60.3 ) QG 69.60.2.6 { l ,QG 69.8,0.2 i } l I T 110011130 2 i 1

BCAP-CSR Elcment i Application of Latest Design Requirements to Previously-Completed Work i The BCAP Program Document provides. in the CSR element, a framework for the verification of construction work completed and 9.c. accepted prior to 6/30/84. The CSR verification consists of inspections and documentation reviews performed using the latest approved design requirements. The appropriateness of using " latest" approved design reIguirements to perform { } inspections or documentation reviews for items completed prior to 6/30/04 is r i discussed in this document. i } t i j The presentation that follows describes: (1) the construction work subject to review; (2) how design requirements are applied in developing inspection i criteria; (3) which design documents, applicable at what, time, are used in each stage of this criteria development; and (4) how the application of the j ' latest" design requirements to "previously completed" work is appropriate in { the context of the SCAP. The consistency of the logic presented with both the BCAP Progras Doctment and CSR implementing procedures is demonstrated by j detailed references where appropriate. ( j .n [ 1. Construction Subject to Review i i j Those safety-related

• items" which were completed. Q.C. inspected and l

3 accepted prior to 6/30/44 are subject to the inspections and documentation reviews in the CUR element (DCAP Prog. Doc. at 11-1 and DCAP-20 para. 4.3). I ] 2. Design Requirement Applicability 1 The verification of design-significant attributes is performed against the latest approved design drawings and specification requirements. (BCAP i l Prog. Doc. at 11-2). The following discusses the acceptability of using i the latest design requirements which. in some cases may not have been j applicable to the item at the time of its construction. The various uses of design requirements in the several stages of verification criteria 1 'I:0011131 I i i (1012J) 1

selection are also discussed. The following discussion also explains why generic design requirements may be used for determining checklist attributes for reinspection or documentation review, while other item-specific design requirements may be used in preparing item-specific acceptance criteria. A. Checklist Attributes (Use of Generic Design Requirements) Attributes for reinspection or for documentation review are identified by reviewing the latest design drawings, specifications, and other documents which are applicable at the time of the population checklist / instruction preparation (BCAP-22, para. 4.1.1 and 2). Considering the BCAP work schedule, the applicability date for these design documents will be 6/30/84 or later. Those attributes considered design significant are identified from these documents (BCAP-22, para 4.1.3). For the purposes of BCAP CSR verifications, the use of design requirements in existence on or af ter 6/30/84 is acceptable. Generic . design requirements for any given ites within the scope of CSR may i have been eliminated, relaxed, or made more stringent subsequent to that item's installation date. If a requirement has been eliminated, the original requirement by itself could not have been desi7n significant. Any relaxation in the design requirements is acceptable in that the new requirement will automatically allow acceptance of the existing installation. Hence, compliance in these cases need not be verified by BCAP. If the design requirements have become more stringent subsequent to an item's installation, provisions within BCAP allow for the invalidation of observations that result from application of the more atringent requirement, but meet the original requirements (DCAP Prog. Doc. at II-2 and BCAP-06, para. 4.3.3c). Hence, the BCAP results are not affected by the use of any design requirements effective on or after 6/30/84. 110011112 (1012J)

i I ' B. Package Preparation (Use of item-Specific Design Requirements) The latest design drawings applicable to the item, as available at the l time of package preparation, are required to be included in the package by BCAP procedure (BCAP-23, para 4.2.2g). However, any drawings applicable on or after 6/30/84 would be satisfactory for BCAP l l purposes. Since the item was final 0.c.taccepted prior to 6/30/84, the current revision of the drawing should reflect the existing installation of the item. If the item design has changed since the item's installation and the item has not been reworked, an observation is generated and subsequently invalidated based on the item's acceptability at the time of installation (BCAP Prog. Doc. at 11-2 and BCAP-06 para. 4.3.3c). If the ites design had changed and the item had been reworked after 6/30/84, then the item would be considered to have been erroneously included in the population and no longer subject to CSR review. . n-3. Methods of Verification and Acceptance Criteria A. Reinspection For each design-significant attribute that is accessible and recreatable, a method of verification is developed and incorporated into the checklist instruction. Acceptance critoria are, in most cases, developed free the latest design drawings and specification requirements. However, inspection criteria may be relaxed free design requiremonts where the original inspection criteria are overly j restrictive from a design-significance standpoint [BCAP-22 para 4.4.1, i 4.4.2 (a,b)). These alternate inspection criteria are reviewed by the Architect / Engineer (DCAP-22, para. 4.6.5 and letter N.N. Xaushal to D. Fischer 9/10/04). 110011133 (1012J)

~4-B. Documentation Review tach design-significant at tribute which is required to be documented to support the hardware installation is identified by latest specification, code, standard.,or regulatory requirements at the time of instruction preparation. The detailed methods of verification are based on contractors' procedures in effect at the time of installation, if these procedures meet or exceed the specification, code, standard, or regulatory requirements. If these procedures do g not meet or exceed this requirement, a generic observation is generated by the CSR Engineering Section for the particular attributes which are potentially inadequately addressed by the contractors' procedures. 4. Conclusion The application of the latest design requirements to the verification of previously completed work, as currently perforced in the BCAP CGR verification, is appropriate and correct. This conclusion is supported by the equivalence in the results of CSR when the latest design, the design applicable at the time of construction, or the design as of 6/30/84, is applied to an item. The 6/30/04 date merely determines the scope of previously completed work included within the esR review, Referenced procedures: BCAP-06 Revision 7 BCAP-20 Revision 2 BCAp-22 Hevision 1 BCAP-23 Revision 1 110011134 (1012J)

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...,o v. February 25, 1985 BRD el4.902 TO: N. N. Kaushal l l FROM: N. P. Smith l RE L, AIR-009 In referenco to your respoque to the above AIR, we understand your response to Itom 1. however, provido to Quality Assurance the sourco document uced to dotormino the accept / reject critoria for qualifications of Electrical Inupactors if Comstock Procedure 4.0.3 was not used. Since Item 2 in the "Doncription of Action Roquestod" of AIR-009 was not responded to, we will tophrano the quantion no that you can more fully understand tho issuo and provide the basis for the question. The DCAP program document discunnon construction Samplo Reinspection in torms of items which woro constructed and inspected prior to June 30, 1904. Thoroforo, the uno of design documents dated after Juno 30, 1904 cooms to be outsido the program commitmonto. Tho tophracing of the quantion (! tem 2) is ao follows: We would like you to juctify the basis for your CSR ongineers not using the specifications, drawingo, and other design documents which woro in offect an of June 30, 1904. Pleano respond to.thic roquest by 4:00 P.M. on February 20, 1905. l c y, N. P. Smith Conocal Suporvisor 0.A. Braidwood Station NPS/ PAL /mjv (03700) cci E. It: patrick f...hQ$(l}V

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..- - ---_ - -._ -.- ~_ 1 4 t ? 1 1 hKSPONSE TO UCAP Q A. AIR ti 000 2 1 1 f 1 4 Comstock procedure 4.8.3 was upql,used as a source of attributes r verification in accordance with Para. 4.1.2 and 4.1.3 of Pr i r ng

22. Rev.1 in the development of CSR-R-0-ELE chocklist and instruc j

Refer to the memo written as required by Para 4.3.2 for this checklist j ( and instruction. 1 1 { 1 verification of certain attributes identified in C3R-i Procedure 4.8.3 was utilized. utilized in developing the methods of verification. Revision F and earltor rev i utilized because it was not in effect at the time of checklistRevis j t preparation, which began in November 1984 and was completed and the preparer on January 2. 1985. i I 5 i NOTE j Paragraph 4.1.2 of 8 CAP-22. Nev. i is the applicable paragraph. BCAP 23 Rev.1, which both identify the requireme i j { selection of design drawings for attribute artlection and 4 package contents, respectively, are applicable to the use of l i contractor procedures in the development of checklists and j instructions. I I 1 t i h l ) i l l l l l f I i I t 4 9.,,.,, 090'1J 110011137 i j I l i i Y

SHEET / OF, ) OMONVEALTH EDISON Co. ACTION ITEM REQUEST (1) AIR NO.OO9 1 2) ISSUED T0/ TITLE (3) ORGisNIZATION (l1) DATE ISSUED (4) SURVEILLANCE fl. Al. McL uf k I i ggf AUDIT _ REVIEV[' .D*fEciOr f / OTHER

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RESPONSE TO BCAP Q.A. AIR 8-009 Comstock procedure 4.8.3 was Dol used as a source of attributes requiring verification in accordance with Para. 4.1.2 and 4.1.3 of Procedure BCAP-22, Rev.1 in the development of CSR-R-0-ELE checklist and instruction. Refer to the memo written as required by Para 4.3.2 for this, checklist and instruction. However, in the development of ins.tructions on the detailed methods of l verification of certain attributes identified in CSR-R-G-ELE, Comstock Procedure 4.8.3 was utilized. Revision F and earlier revisions were utilized in developing the methods of verification. Revision G was not utilized because it was not in effect at the time of checklist preparation, which began in November 1984 and was completed and signed by the preparer on January 2, 1985. NOTE: Paragraph 4.1.2 of BCAP-22, Rev. 1 is the applicable Paragraph. Neither para. 4.1.1 of BCAP-22 nor para. 4.1.2.0 of BCAP 23 Rev. 1, which both identify the requirement for the selection of design drawings for attribute selection and package contents, respectively, are applicable to the use of contractor procedures in the development of checklists and instructions. i e , 78 <*( 5 l 09kJ h00111:j9 l

_= i February 15,_1985 BCAP Memo 9686 i f l TO: N. P. Smith, Q.A. l FROM: G. M. Orlov i An extension is requested for the response due dates for Ala 8 and 9. A response will be provided by 2-22-85. i 1 ~ i

• . M.

Orlov j GM0/sjs I ) cc: BCAP File QG 69.60.3 t QG 69.60.2.6 i i QG-6P.-9hih '0.. .a 1 i [ 4 i t h L i l l l I 110011140 1 1 \\

Q & 69 M./.G 0 o o,.) February 8, 1985 BRD #14.819 TO: N. Kaushal BCAP Director'

SUBJECT:

AIRS - 008/009 / / The subject AIRS were issued and hand delivered on Friday. Febr.uary 1, 1985. Responses were requested by February 5 and 6, 1985 respectively and are currently ovekdue. Please advise when they will be returned. A N. P. Smith General Supervisor O.A. NPS/WMS/nlw (0254B) i cc: M. J. Wallace E. E. Fitzpatrick O. A. File - 71.12 (008/009) 71.7 (Chrono file) $l]@]T3% o , 1 s I( F EB 0 3 FiC0 \\ t B.C.A.P. D 110011111 i 2 :.. n ! z

/ f fy o fs -- ~.- SHEET / OF COnta.ONVEALTH EDISON CO. ACTION ITEM REQUEST (1) AIR NO. 009 (2) ISSUED TO/ TITLE (3) ORGANIZATISN (11) DATE ISSUED (4) SURVEILLANCE _ g,Al.d'a.ufka-I .D i f E(io r gg{ AUDIT REVIEV g // OTHER (5) ACTIVITY / SUBJECT AREA 'h' * * % > ch ee.L l. s +) s nshoc f *. (6) REFER ac.ap-D.:t DO$ CENT (S) IC C b L p. c~ .t Prepa r +:On ace.13 u 4. t. 2 6c ( ATED Y/ TITLE (10) APPROVED BY/ TITLE (12) RESPONSE DUE DATE sw a % v s d L :,, u z/a/ss '8) 0 0ESCRIPTION OF ACTkI N REQUESTED AA wm d mk J @d n -J M % e w.D ea-snLaN. 4 m. mP dd wq AW man (h3 Ju d W>d/w 'j j 'f,"'""'R'];ec & a D J m M yf % Me w g a_) w+. r g C% Aws DI.I +'d s a ~,a ' D. t.x. m p-.).~. L. eLAL v + '=~,? R "Y 9. , o.r uea e>/w .AN d* 4 r N s r % A W ^e /;.) bs. a w se1s4/ "e*e n WM 4 @*# d 13) RESPONSE 'DESCRIPTICN OF ACTION TAKEN OR ATTICN PLANNED) l 6.

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i t ACTZON ITEM REQUEST FORM COMPLETICN OUIDELINES j RESP. t BLOCK ORG. PERSON WHAT/WHEN/VHERE/HOW (AS APPLICABLE) f (1)-(12) BCAP Q.A. Originator (see QASI-17.) l (13) Responsible Engineer Describe the action taken or planned to resolve action j Organization requested by Q.A. (14) Insert date the action completed or planned to be ] completed. (15) Supvr. After review of (8) through (14), indicate approval of ', 4 i response by signing and inserting date. (16)-(18) DCAP Q.A. Q.A. Person (see QASIgl7.) cen. Supvr. l i i l 3 i s. l l f 1 1 H0011143 i I .,&h. w w. .~ i -}}