ML20214D296

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Intervenor Exhibit I-ROREM-143,consisting of 851011 Rev 10 to Project Procedure BCAP-06, Observation & Discrepancy/ Concern Processing. Observation Record Forms & Form Instructions Encl
ML20214D296
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 10/02/1986
From: Kaushal N
COMMONWEALTH EDISON CO.
To:
References
OL-I-ROREM-143, NUDOCS 8705210278
Download: ML20214D296 (32)
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{{#Wiki_filter:0' b f$f~Y _f~ rgm1 yl0 t s $/3li6 9(? Commonwealth Edison g7 TITLE: OBSERVATION AND DISCREPANCY / CONCERN PROCEDtIRE NU!!BER: PROCESSING mFF C0c BCAP-06 ~ u BRAIDWOOD NUCLEAR STATION PROJECT ' PROCEDURE REV. DESCRIPTION APPROVALS DATE Delete QA ccpies of Oririnator b*b* INN I Observations; revise validity check usin Prni _ 's En e. N/A gggic @; "*g 6 3 Q.A. Suot. MI bh fdM Proi. Hzr. /Y/Wh Delete Asst. Director-CSR Oririnator N.N. N/'/hf' frem approval chain for valid observations: Request NCR Proi.'s Enr. N/A 7 after approval of observation O.A. Sunt. 8/75I b>' k - SlMC ~ < ls. Proi. Mgr. . YZ' $f s, Clarified method 'for process-ing of invalid observations Oririnator M,U, N[lN 8 deleted S&L evaluation for ; Proi.'s Eng. 5/A selected CSR discrepancies Q deleted requirements for re-0.A. Sunt. Wi _Y M M Istd n' lease of construction hold; a r other minor changes. RP5fesacuna Proi. Mgr. NO YM/[ hse aihnso Originator ((N, (AMhd 37}8[ 6 V

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  • b 6I3l[F other minor changes.

Prof. Mer, t / oricinator M N KAA44dfLQ. l0[3/6 . F.i - 'f m g{.E( M 10 Incorporated procedure g Proi.'s Eng. N/A o change notice numbers O.A. Suot. 7M k[ k - /O(( j}. A' h. 1, 2, 3 and 4. Proi. ?fgr. 1% 04 S - o 'o l's k Wy e -{ m oririnster '9E Proi.'s Eng. 2hh N 6 0.A. Sunt. liTA 11000S20 6 's-G u s Proi.Jfgr. l - - - - - ~ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ ~ - -

s + ~ 1 1 Commonwealth Edison Braidwood Nuclear Power Station REVISION PROCEDURE MNBER PAGE 2 0F 25 10 BCAP-06 1.0 PURPOSE The purpose of this procedure is to: Establish the method by which each observation is documented and 1.1 processed. Establish methods for providing a record summarizing those observations which are processed and their disposition. 1.2 1 Provide for the review of discrepancy and concern compilations. 1.3

2.0 REFERENCES

Reporting Quality Wonconformances During Construction Tests. 2.1 QP 15-1 CSR Performance of Reinspection and Document Review. 2.2 BCAP-24 RPSR Review of Contractor Procedures 2.3 BCAP-43 2.4 BCAP-60 RSCAP Review Methods. 2.5 BCAP-03 Records Management. Interface with contractors and Architect / Engineer. 2.6 BCAP-04 i 2.7 BCAP-25 CSR Evaluation of Results, i 2.8 BCAP-07 BCAP Reports. t 3.0 POLICIES / DEFINITIONS

3.1 Definitions

1. Observation (CSR and RSCAP)-An apparent difference in attribute from that defined as acceptable by the applicable checklists, a. instructions or drawings which is observed while verifying the acceptablility of that attribute, RPSR-An apparent difference in a contractor procedural requirement and the applicable FSAR or Sargent & L. undy. b. specification requirement. liOODS297 (1575J)

s \\ i 3 Commonwealth Edison Braidwood Nuclear Power Station PROCEDURE MIMBER REVISION 10 PAGE 3 OF 25 BCAP-06 2. Discrepancy An observation which has been reviewed by the BCAP CSR: a. Task Force against the design drawings and specifications, lists of existing discrepancies, and the construction status reports to ensure that the observation is not incomplete work, the subject of a design change, or a duplication of an already documented condition. A discrepancy is a difference in an attribute of completed QC accepted construction between that required by approved design drawings and specifications and that observed by inspection or review of quality documentation. An observation which has been reviewed by the BCAP RSCAP: b. Task Force, determined to be valid, and represents the lack of fulfillment of a specific corrective program objective. Concern - A validated difference between (1) Coiuitruction 3. requirements of the FSAR and Architect / Engineer specifications and (2) contractors procedures, as identified by performance of the Reverification of Procedures to Specification Requirements (RPSR) element. 4. Desian-Stanificant Discrepancy - A discrepancy in the construction of an item from the approved design which, if a uncorrected, could impair the itee's ability to perform its safety-related design function under design loadings and conditions. This applies to the CSR element only. 5. Programmatic Discrepancy - A discrepancy whose root cause lies in a procedural or programmatic deficiency. This type of discrepancy is likely to be repetitive in nature in that the discrepancy is expected to occur wherever the deficient procedure or program is applied. 6. Wonconformance Report (WCR) - Documented evidence of a nonconforming condition which is processed by emalth Rdison Company or its contractors so as to determine corrective action required and relay the corrective action information to those responsible for implementation. The standard form used by c m alth Edison Company for nonconformance reporting is the Reference 2.1 Nonconformance Report, Fora QP 15-1, which will be referred to in this procedure as a "NCR". 110008298 (15*15J)

4 \\ + r s Commonwealth Edison Braidwood Nuclear Power Station REVISION PROCEDURE MIMBER 10 PAGE 4 0F 25 BCAP-06 DBMS - Any data base management system used by BCAP to (1) control and report the status of CSR Verification Packages (CSR 7. Package tracking file) and (2) track the processing ofExhibit a observations (Record of Observations tracking file). provides an example set of file headings in the Record of Observations tracking file. Observation Preparation - Observations may be prepared by BCAP inspectors, doctment reviewers, or engineers performing work in 3.2 accordance with References 2.2, 2.3, and 2.4 or other BCAP i procedures. 4.0 PROCEDURE Use Section A for CSR, B for RPSR, or C for RSCAP, as appropriate. A. PROCEDURE FOR CSR ELEMENT If the preparer of an observation is an engineer, the discipline lead engineer shall perform the functions of the lead discipline inspector below. 4.1 Recordino of Observations ,se PREPARER Record each observation identified during reinspection or 1. documentation review on Part 1 of the BCAP Observation Record Forn 06-1 (Exhibit A) in accordance with the instructions of Exhibit A for Part 1 of the form. Assign a unique number to the Observation Record form in 2. accordance with the instructions of Exhibit A. 4.2 Observation Clarity. O oleteness, and Accuracy Review LEAD DISCIPLINE INSPECTOR - CSR i Review the entries on Part 1 of the Observation Record form for 1. clarity, completeness, and accuracy. Return, to the preparer, observations which require additional informatico, clarification or other changes. The preparer shall 2. return the revised form for further processing as below. 110008299 (1575J)

4 i Commonwealth Edison Bratowood Nuclear Power Station REVISION PROCEDURE MNBER 10 PAGE 5 0F 25 BCAP-06 Record the determination of the observation's suitability for further processing in accordance with the instructions of 3. If the observation is not Exhibit A for Part 2 of the form. suitable for further processing, return it to the preparer. Otherwise, proceed to step 6. PREPARER If in agreement with the Review the returned form. determination that the observation is not suitable for fu 4. processing and therefore to be closed, enter a note to this k effect in Part 2 of the form, sign and date the note, and return i the form to the Lead Discipline Inspector for further process ng per steps 6 and 8. If disputed, enter a note to this effect in Part 2 of the form, sign and date the note, and return the form to the Lead 5. Discipline Inspector, requesting that the observation be forwarded to the CSR Lead Discipline Engineer. LEAD DISCIPLINE INSPECTOR - CSR Provide a copy of the completed page 1 of the observation Recor form to the Planning and Scheduling Engineer for initiation of 6. the observation Record file. If the observation is disputed or suitable for further l processing, place the completed page 1 of the Observation R 7. 1 form in the verification Package in accordance with Reference 2.2 and forward the package to the CSR Lead Discipline Proceed to step 4.3. Engineer. If the observation is to be closed, provide the original Observation Record form to the Records Administrator for 8. retention per Reference 2.5. Evaluation and Determination of Validity 4.3 PLANNING AND SCHEDULING ENGINEER Initiate a record of the observation by creating an entry in the Use Exhibit B as an example of 1. DBMS observation Record file. the file headings. LEAD DISCIPLINE ENGINEER Review Parts 1 and 2 of the observation Record form for clarity Refer to the applicable verification package 2. and completeness. and other material used in the Reference 2.2 work. Il0008300 (157M) n

0 Commonwealth Edison Braidwood Nuclear Power Station PROCEDURE MMBER REVISION BCAP-06 10 PAGE 6 OF 25 3. Request additional documents, not a part of the verification package, from the Project Construction Department and/or contractors, as necessary, and perform a review for validity as follows: a. Determine if the observation is valid per the Architect / Engineer-specified design using applicable drawings and their notes, Engineering Change Notices, Field Change Requests, and other requirement documents. b. Review previously-issued Monconformance Reports and contractor-contro11sid deficiency record documents to determine if the observation duplicates an already-identified condition. An observation documented by an existing NCR or other controlled system that is (1) open or (2) closed with a disposition of either " accept as is" or " repair" but not " rework" is to be considered as an invalid observation. c. Determine if the observation documents a condition which is in accordance with the requirements that applied at the time of the original inspection. In this case, the observation is to be considered invalid. If a design change was made after the item was constructed, a meno should be sent to PCD advising that this situation exists and may require further action. If Architect / Engineer (S&L) documentation exists that exempts the item fr a the change, then the meno to PCD is not required. d. If (1) the observation documents a condition that is subjective in nature, such as a visually-determined weld attribute and (2) a Level II Inspector performed the inspection, then a Level III Inspector of the applicable discipline may be requested to make a determination of the acceptability of the condition per the original verification package. This determination shall be documented on page 1 or in a supplemental sheet to page 1 and be signed by the Level III Inspector. e. Determine if the observation documents a result of construction-related damage. In this case the observation is to be considered outside BCAP scope (neither valid nor invalid). 110008301 (1575J) -,m., ,4-

r = O Commonwealth Edison Brenswood Nuclear Power Station PROCEDURE MIMBER REVISION BCAP-06 10 PAGE 7 OF 25 f. Determine if the observation identifies a condition which may have occurred subsequent to the initial installation and first-line QC inspection. Walkdowns and tests are usually i developed to assure that such subsequent conditions are identified. Additionally, some construction activities are completed in conjunction with testing programs. For this type of observation, process the observation as outside BCAP scope (neither valid nor invalid). Ensure that approved documents or procedures (applicable to Byron or Braidwood) .will provide reasonable assurance that the observation would have been identifie$ during the walkdown/ test. The applicability of specific walkdown/ tests for use in determining whether any particular type of observations need be processed as BCAPdiscrepancies will be determined on a case by case basis for each walkdown/ test and type observation. g. If (1) the observation documents a condition which does not pertain to'a sample ites or documents a condition for a sample ites that does not apply to a specific checklist instruction requirement and (2) the observation is determined (with the assistance of the Architect / Engineer, if requested) to have no potential for design significance, i then process the observation as outside of BCAP scope (neither valid nor invalid). h. Determine if the observation identifies a condition which may have occurred subsequent to the initial installation and first-line QC inspection and would have been identified or corrected in a subsequent sequential installation inspection procedure. For this type of observation, process the observation as outside BCAP scope (neither valid nor j invalid) provided the subsequent sequential installation / inspection procedure was approved prior to the date for population sample selection, is a current procedure in use, identifies work tasks which address the specific observation i being evaluated and provides reasonable assurance that the i observation would have been identified or corrected during j the course of the subsequent installation / inspection process. 1. If an observation identifies a condition which is associated with a portion of an ites that has not been Q.C. accepted at the time of the BCAP inspection, then that portion of the observation may be determined to be invalid. I liO O O M 0 2 (1575J) l

~ Commonwealth Edison Braidwood Nuclear Power Station PROCEDURE MIMBER REVISION BCAP-06 10 PAGE 8 op 25

j. Determine if the observation should be considered invalid or outside BCAP scope for reasons other than provided above.

In this case, provide specific justification of why the observation is invalid or outside BCAP scope.(Note: This determination ultimately requires the approval of the BCAP Director.) 4. Initiate a Page 2 of the BCAP Observation Record form by recording the observation evaluation and validity determination on Part 3 in accordance with the instructions of Exhibit A. Include, in the evaluat4on, the specific justification for a determination that an observation is invalid. Provide (attach or reference) any supporting documentation not already included with the observation. Provide the specific reason for a determination that an observation is outside BCAP scope. Sign Part 3 as the evaluation and determination reviewer. Note: At this point, a valid observation is called a discrepancy. 5. If the entire observation was determined to be valid, go to step 4.5. If the observation was determined to be part valid and part invalid, process it as an invalid observation per step 4.4 and then perform any steps-in 4.5 not already performed. Process invalid observations per step 4.4. Process observations outside BCAP scope per step 4.8. a 6. If additionai information regarding validity is provided by PCD after an observation is determined to be valid, re-evaluate the validity determination. 4.4 Processino of Invalid Observations LEAD DISCIPLINE ENGINEER 1. Return the observation Record form Pages 1 and 2 to the Lead Discipline Inspector. LEAD DISCIPLINE INSPECTOR 2. Review the observation evaluation and validity determination. Discuss the validity determination with the original preparer. If the original preparer is no longer assigned to BCAP or is not on-site, discuss with the preparer's immediate or higher supervisors within BCAP. If additional information is available which may affect the validity determination, add the information to Part 1, annotating the new entry with date and signature. 11003S303 (15'15J)

O \\ Commonwealth Edison Braidwood Nuclear Power Station PROCEDURE MIMBER REVISION BCAP-06 10 PAGE 9 0F 25 3. If in agreement that the observation is invalid, document the acknowledgment on Part 3 of the form. If an observation is declared invalid based on a Level III inspector's determination of a subjective condition, (step 4.3.3.d or 4.6.1), agreement with the preparer is not required, however, the preparer or, if the preparer is no longer assigned to BCAP or is not on-site, the preparer's supervision, should sign in block 19 of Exhibit A acknowledging review of that determination. Forward the form to the Supervisor, and proceed to step 8. 4. If not in agreement, return the forms to the Lead Discipline Engineer for reconsideration per section 4.3. LEAD DISCIPLINE ENGINEER 5. If agreement cannot be achieved, have a review performed by a group designated by the Assistant Director-CSR/RPSR that will reccenend a resolution to the BCAP Director, t.t.c : akas the final validity determination. Enter the final resolution on Part 3 of the form with the BCAP Director signing for approval. 6. Provide a copy of the completed pages 1 and 2 of the form to the Lead Inspector for the information of the preparer. 7. If the observation is still considered invalid, forward the .s original completed peges 1 and 2 to the Records Administrator and perform steps 10 to 13 below. If considered valid, forward the original completed pages 1 and 2 to the Administrative Engineer and proceed to Section 4.5, performing steps 5 through 10. SUPERVISOR 8. Review, sign and date the form. Forward the form to the Records Administrator. 9. Where the observation has been invalidated per step 4.3.3 (J) obtain BCAP Director's approval. RECORDS ADMINISTRATOR

10. Provide a copy of the completed page 2 of the Observation Record form to the Planning and Scheduling Engineer.

110008301 (1575J)

4 Commonwealth Edison Braidwood Nuclear Power Station PROCEDURE MIMBER REVISION BCAP-06 10 PAGE 10 OF 25 j

11. Provide a copy of pages 1 and 2 to the RPSR Supervisor and the RSCAP Supervisor. Provide copies to PCD and S&L if the observation had previously been determined to be valid and this is a revision.
12. File the completed original pages 1 and 2 per Section 5.

PLANNING & SCHEDULING ENGINEER

13. Enter into the DBMS file the result of the validity determination and the date of that determination from the provided copy of page 2 of the observation Record form.

4.5 Processing of a Discrepancy (valid observation) LEAD DISCIPLINE ENGINEER 1. Forward the original of Pages 1 and 2 to the CSR Supervisor. SUPERVISOR 2. Review the discrepancy and, if necessary, request further evaluation per steps 4.3.3.a to 4.3.3.g. If in agreement with the validity evaluation and determination, indicate review by signature. Indicate "N/A" in item 22 of Exhibit A. 3. Determine the need for Architect / Engineer evaluation of the design significance of discrepancies related to documentation review and indicate that need in item 20 of Exhibit A. Evaluation by the Architect / Engineer of discrepancies related to reinspections shall be required. Architect / Engineer review of documentation discrepancies is only required when the discrepancy is directly related to a possible physical defect in the construction and its design significance can be determined. Examples of such discrepancies are: a) Incorrect type or grade of installed material. b) Incorrect size of installed material. 4. Forward the completed Pages 1 and 2 of the observation Record form to the Administrative Engineer. 110008305 (1575J)

4 ~ l p ~ O' Commonwealth Edison l Braidwood Nuclear Power Station PROCEDURE MNBER REVISION BCAP-06 10 PAGE 11 OF 25 ADMINISTRATIVE ENGINEER 5. Request, by meno, the Superintendent-Project Construction Department to issue an NCR referencing the discrepancy and to provide BCAP with a copy of the NCR. Provide sufficient information to prepare an NCR per Reference 2.1, including a copy of the Observation Record form. pages 1 and 2. Indicate on the copies that there is no page 3. This meno shall request that no corrective work on the hardware may proceed until the design significance has been determined and PCD is so advised. The meno shall also regtpst PCD. to provide specific information, if any, that may affect the validity determination of the observation. w 6. Provide a copy of the Page 2 of the observation Record form to the Planning & Scheduling Engineer for recording of the validity determination result in the DBMS Observation Record file. 1. If evaluation is required by item 20 of Exhibit A, forward a copy of pages 1 and 2 of the discrepancy to Sargent & Lundy for evaluation, retaining the originals of Pages 1 and 2. Have the Planning and Scheduling Engineer make the appropriate DBMS entry regarding the date sent to S&L. 8. Provide a copy of Pages 1 and 2 to the Assistant Director - .9 CSR/RPSR, the RPSR Supervisor and the RSCAP Supervisor and the original completed Pages 1 and 2 to the Records Administrator. 9. Enter the NCR number, when received, into the DBMS file for that observation. PLANNING & SCHEDULING ENGINEER

10. Record result of validity determination and the date of transmittal to S&L in the DBMS Observation Record file.

4.6 Evaluation of Discrepancy SARGENT & LUNDY (S&L) 1. Provide comment, if appropriate, (in part 4) on the potential invalidity of the CSR discrepancy. If appropriate, provide specific information and supporting documentation that would permit a re-evaluation of the validity determination by the Lead Discipline Engineer. If the observation documents a condition that is subjective in nature, such as a visually-determined weld attribute, then S&L may request a Level III Inspector of the applicable discipline to make a determination of the 1i000S306 (157M)

Commonwealth Edison Braidwood Nuclear Power Station PROCEDURE MNBER REVISION BCAP-06 10 PAGE 12 0F 25 acceptability of the condition per the ;riginal verification package. This determination shall be documented on a supplemental sheet to page 3 and be signed by the Level III Inspector. 2. For valid CSR discrepancies, deterair.e the design significance. If appropriate, supplemental information provided by the BCAP Inspector may be included in the evaluation. Document the results of this review, including references to design calculations, if any. For those CSR discrepancies that are considered design signifsicant, provide comments regarding the potential root cause and evaluate the potential generic aspects of the discrepancy. 3. Initiate a Page 3 of the BCAP Observation Record form by completing Part 4 in accordance with the instructions of Exhibit A. Forward Page 3 of the form to the Administrative Engineer. ADMINISTRATIVE ENGINEER 4. Provide, by meno, the Planning and Scheduling Engineer with the receipt date of Page 3, design-significance determination, and root cause summary for DEfts tracking. 5. Transmit original of Page 3 of the form to the appropriate CSR Lead Discipline Engineer. PLANNING & SCHEDULING ENGINEER 6. Enter in the DBMS file the date, result of the design significance review and root cause as supplied by the Administrative Engineer. 4.7 BCAP Review LEAD DISCIPLINE ENGINEER 1. Review the S&L evaluation. If the discrepancy is design significant, determine the root cause. Record comments on Part 5 of Page 3 of the observation Record form and sign as l reviewer. Where S&L has provided comments as to the validity of i the observation, review these comments, and if appropriate, I reprocess the observation as invalid per Steps 4.3.2 through ( 4.4.13 as necessary. 2. Forward the S&L evaluation and any comments to the Supervisor for signature. U000S307 (1575J)

4 Commonwealth Edison Braidwood Nuclest Power Station PROCEDURE MIMBER REVISION BCAP-06 10 PAGE 13 OF 25 SUPERVISOR 3. Review S&L and Lead Engineer evaluations. Sign Part 5 of the form, acknowledging review. 4. Forward the completed original Observation Record form Page 3 to the Records Administrator. 5. Perform additional review per Section D. Review of Discrepancy / Concern Compilations. t RECORDS ADMINISTRATOR 6. Have the Planning and Scheduling Engineer make the appropriate DBMS entry regarding the file date for the completed observation Record form. 7. For design-significant discrepancies provide copies of Page 3 of the observation Record form to the BCAP Director, the BCAP Assistant Director - CSR/RPSR, the RPSR Supervisor, and,the RSCAP Supervisor. 8. Provide a copy of page 3 to PCD if the observation has been changed from valid to invalid in Part 5 of the form. 4t6 observation outside BCAP Scope LEAD DISCIPLINE ENGINEER 1. Forward the original of pages 1 and 2 to the CSR Supervisor. SUPERVISOR 2. Review the discrepancy and, if necessary, request further evaluation per steps 4.3.3.a to 4.3.3.g. If in agreement with the evaluation and determination, indicate review by signature. Indicate "N/A" in item 22 of Exhibit A. 3. Forward the completed pages 1 and 2 of the observation Record form to the Administrative Engineer. ADMINISTRATIVE ENGINEER 4. Provide, by meno, the Superintendent-Project Construction Department a copy of the observation outside BCAP scope, pages 1 and 2. Indicate on the copies that there is no page 3. This meno should indicate that the observation is being provided so that PCD may address the condition through normal PCD channels outside of BCAP. 11000S308 (1575J) r .. - +,,. _. _ _.

s Commonwealth Edison Braidwood Nuclear Power Station PROCEDURE MIMBER REVISION BCAP-06 10 PAGE 14 0F 25 5. Provide a copy of the page 2 of the observation Record form to the Planning and Scheduling Engineer for recording of the validity determination result in the DBMS Observation Record file. 6. Provide the original completed pages 1 and 2 to the Records Administrator. 7. If an NCR is issued for the observation, enter the NCR number into the DBMS file. PLANNING AND SCHEDULING ENGINEER 8. Record result that the observation is outside BCAP scope and the file date in the DBMS Observation Record file. l 1i000S309 (ts75a) l

s Commonwealth Edison Srsidwood Nuclear Power Station PROCEDURE MIMBER REVISION BCAP-06 10 PAGE 15 OF 25 B. PROCEDURE POR RPSR ELEMENT ~c 1 4.1 Recordino of Observations PREPARER ) 1. Record each observation identified during procedure review on Part 1 of the BCAP Observation Record Form 06-1 (Exhibit A) in accordance with the instructions of Exhibit A for Part 1 of the form. \\ 2. Record a unique number,'obtained from the Assistant Supervisor, on the Observation Record form (Exhibit A). 3. Provide a copy of the form to the Planning and Scheduling Engineer and send the original to the Supervisor for processing. PLANNING AND SCHEDULING ENGINEER 4. Initiate a record of the observation by creating an entry in the DBMS Observation Record file. Use Exhibit B as an example of the file headings. 4.2 (Not Used) 4?3 Evaluation and Determination of Validity SUPERVISOR 1. Review Part 1 of the Observation Record form for clarity, completeness, and accuracy. Refer to checklists, specifications and other material used in the Reference 2.3 work. ) 2. Request PCD, by meno, to provide written comments to BCAP, incorporating Site QA and S&L counnents, if any, on the observation and the potential effect of the observation on completed, ongoing, and future construction. Comments for PTL are to be provided to BCAP by Site QA, incorporating PCD and S&L comments. 3. Request Site QA and S&L, by meno, to provide written comuments to PCD, if any, on the observation and the potential effect of the observation on completed, ongoing, and future construction. Comments for PTL, if any, are to be provided to Site QA by PCD. l 110008310 (1575J) 1

^ ~ Commonwealth Edison Braidwood Nuclear Power Station PROCEDURE MNBER REVISION BCAP-06 10 PAGE 16 op 25 4. Review comments from PCD, Site QA, and S&L, as applicable, and determine the validity of the observation. An RPSR observation may be considered invalid"if the observation is associated with an FSAR or specification requirement which meets any of the following conditions: The requirement (or related observation) a. is not within the contractor's scope of work. b. is also contained in installation drawings required to perform the installation and inspection, or in contractor-generated installation or inspection checklists. c. is not essential to the construction or inspection of any item (i.e. the lack of implementing this requirement can have no adverse effect on the hardware); or, if related to a documentation requirement, will not result in la:k of information (which is not otherwise available) that would render the quality of the associated hardware indeterminate. (NOTE: This is not to be used where the observation identifies deviations from specific FSAR commitments. ) d. is applicable to contractor's work not begun as of 6/30/84. e. was previously addressed by an WCR, QA audit or surveillance, or other deficiency tracking dociumant. f. has been subsequently corrected by either a requirement or procedure change, and it can be shown that previously completed construction or documentation has not been adversely affected. g. is alternately addressed. In this case, provide reference to information (such as contractor, QA, PCD, or S&L provided information) that substantiates why the observation does not represent a concern with the adequacy of construction or documentation. (This determination ultimately requires the approval of the BCAP Director.) 5. Initiate a Page 2 of the BCAP Observation Record form by recording the observation evaluation and validity determination on Part 3 in accordance with the instructions of Exhibit A. Include, in the evaluation, the specific justification for a determination that an observation is invalid. Provide any supporting documentation not already included with the observation. Sign Part 3 as the evaluation and determination reviewer. Note: At this point, a valid observation is called a concern. (1575J) 110008311

Ct mmonwealth Edison Bra owood Nuclear Power Station PROCEDURE MMBER REVISION BCAP-06 10 PAGE 17 OF 25 6. If the observation was determined to be valid. go to step 4.5. 7. If additional information regarding validity is provided by PCD, i S&L, or others af ter an observation is determined to be valid, re-evaluate the validity determination. If the determination is changed from valid to invalid, prepare a revision to Page 2 in accordance with Reference 2.5. 4.4 Processing of Invalid Observations ) { SUPREVISOR g 1. Return the Observation Record form Pages 1 and 2 to the Preparer. If the Preparer is no longer assigned to BCAP or is not on-site, return to the Preparer's immediate or higher i supervisors within BCAP. I PREPARER 2. Review the observation evaluation and validity determination. If additional information is available which may affect the validity determination, add the information to Part 1, annotating the new entry with date and signature. 3. If in agreement that the observation is invalid, document .ir acknowledgment on Part 3 of the form, forward the form to the supervisor, and proceed to step 8. 4. If not in agreement, return the form to the Supervisor for reconsideration per section 4.3. SUPERVISOR 5. If agreement cannot be achieved, have a review performed by a group designated by the Assistant Director - CSR/RPSR that will roccamend a resolution to the BCAP Director, who makes the final validity determination. Enter the final resolution on Part 3 of the form with the BCAP Director signing approval. 6. Provide a copy of the completed pages 1 and 2 of the form to the preparer. 7. If the observation is still considered invalid, forward the original completed pages 1 and 2 to the Records Administrator and perform steps 10 to 13 below. If considered valid, forward the original completed pages 1 and 2 to the Administrative Engineer and proceed to section 4.5, performing steps 4 through 10. 110008312 (1575J)

Commonwealth Edison Srsidwood Nuclear Power Station PROCEDURE MNBER REVISION BCAP-06 10 PAGE 18 0F 25 8. Review, sign and date the form. Forward the form to the Assistant Director - CSR/RPSR. ASSISTANT DIRECTOR 9. Approve the determination and sign and date the form. Forward the form to the Records Administrator. Whers the observation has been invalidated per Step 4.3.4.(g) obtain BCAP Director's approval. RECORDS ADMINISTRATOR 5

10. Provide a copy of the completed page 2 of the observation Record form to the Planning and Scheduling Engineer.
11. Provide a copy of pages 1 and 2 to the CSR Supervisor and the RSCAP Supervisor. Provide copies to PCD and S&L if the observation had previously been determined to be valid and this is a revision.
12. File the completed original pages 1 and 2 per Section 5.

PLANNING & SCHEDULING ENGINEER

13. Enter into the DBMS file the result of the validity se determination and the date of that determination from the provided copy of page 2 of the observatice. Record form.

4.5 Processing of a Concern (valid observation) SUPERVISOR 1. Review the concern, indicating review by signature. Forward to the Assistant Director - CSR/RPSR. ASSISTANT DIRECTOR 2. Review the concern and indicate approval by signature on Exhibit A. 3. Forward the completed pages 1 and 2 of the observition Record form to the Administrative Engineer. 1i0008313 (1575J) 2

O Commonwealth Edison - Braidwood Nuclear Power Station PROCEDURE MNBER REVISION BCAP-06 10 PAGE 19 0F 25 ADMINISTRATIVE ENGINEER 4. Request, by meno, the Superintendent-Project Construction Department to issue an NCR referencing the concern, and to provide BCAP with a copy of the NCR. Provide sufficient information to prepare an NCR per Reference 2.1, including a copy of the Observation Record form, pages 1 and 2. Indicate on the copies that there is no page 3. 5. Provide a copy of Page 2 of the Observation Record form to the Planning & Scheduling Engineer for recording of the validity determination result and file date in the DBMS Observation Record file. 6. Forward a copy of pages 1 and 2 of the concern to the Supervisor for consideration in preparation of the final report per Reference 2.8. 7. Provide a copy'of pages 1 and 2 to the CSR Supervisor and the RSCAP Supervisor and the original completed Pages 1 and 2 to the Records Administrator. 8. If an NCR is issued, enter the NCR number, when received, into the DBMS file for that observation. .,. - PLANNING & SCHRDULING ENGINERR 9. Record result of validity determination and file date in the DBMS Observation Record file. SUPERVISOR

10. Perfcra additional review per Section D, Review of Discrepancy / Concern Ccapilation.

11000S314 (1575J)

o \\ Commonwealth Edison ) Braidwood Nuclear Power Station PROCEDURE MNBER REVISION BCAP-06 10 PAGE 20 0F 25 C. PROCEDURE POR RSCAP ELEMENT 4.1 Recordino of Observations PREPARER 1. Record each observation on Part 1 of the BCAP Observation Record Forn 06-1 (Exhibit A) in accordance with the instructions of Exhibit A for Part 1 of the form. 2. Assign a unique number to the observation Record form in accordance with the instructions of Exhibit A. 3. Provide a copy of the form to the Planning and Scheduling Engineer and send the original to the Supervisor for processing. 4.2 (Not Used) 4.3 Evaluation of Observation PLANNING AND SCHEDULING ENGINEER 1. Initiate a record of the observation by creating an entry in the DBMS Observation Record file. Use Exhibit 5 as an example of the file headings. SUPERVISOR 2. Review Part 1 of the Observation Record form for clarity, completeness, and accuracy. Refer to checklists, specifications and other material used in the Reference 2.4 work. 3. Determine if the observation is valid as follows: a. Determine if the condition is in accordance with the corrective action program documents, b. Determine if the condition is valid per the Architect / Engineer-specified design using applicable drawings and their notes, Engineering Change Notices, Field Change Requests, and other requirement documents. c. Review previously-issued Nonconformance Reports and deficiency records to determine if the observation duplicates an already-identified condition. An observation documented by an existing NCR or other controlled system that is (1) open or (2) closed with a disposition of either " accept as is" or " repair" but not " rework" is to be 110008315 l (1575J) l

Commonwealth Edison Braidwood Nuclear Power Station PROCEDURE MIMBER REVISION BCAP-06 10 PAGE 21 0F 25 i considered as an invalid observation. Open generic NCRs which do not identify the specific item of interest shall not be used to consider an observation invalid. 4. Initiate a Page 2 of the BCAP Observation Record form by I recording the observation evaluation and validity determination { on Part 3 in accordance with the instructions of Exhibit A. { Include, in the evaluation, the specific justification for a 1 determination that an observation is invalid. Provide any supporting documentation not already included with the observation. Sign Part '3 as the evaluation and determination reviewer. Note: At this point, a valid observation is called a discrepancy. 5. If the observation was determined to be valid, go to step 4.5. 6. If additional information regarding validity is provided by PCD, s S&L, or others after an observation is determined to be valid, re-evaluate the validity determination. If the determination is changed from valid to invalid, prepare a revision to Page 2 in accordance with Reference 2.5. 4,, 4 Processing of Invalid Observations SUPERVISOR 1. Return the Observation Record form Pages 1 and 2 to the Preparer. If the Preparer is no longer assigned to BCAP or is not on-site, return to the Preparer's impediate or higher supervisors within BCAP. PREPARER 2. Review the observation evaluation and validity determination. If additional information is available which may affect the validity determination, add the information to Part 1, annotating the new entry with date and signature. 3. If in agreement that the observation is invalid, document the acknowledgment on Part 3 of the form, forward the form to the Supervisor, and proceed to step 8. 4. If not in agreement, return the forms to the Supervisor for reconsideration per section 4.3. 110008316 (1575J) {

e Commonwealth Edison Braidwood Nuclear Power Station PROCEDURE MIMBER REVISION l BCAP-06 10 PAGE 22 OF 25 SUPERVISOR 5. If agreement cannot be achieved, have a review performed by a group designated by the Assistant Director - RSCAP that will reccommend a resolution to the BCAP Director, who makes the final validity determination. Enter the final resolution on Part 3 of the form with the BCAP Director signing for approval. 6. Provide a copy of the completed pages 1 and 2 of the form to the preparer. t 7. If the observation is still considered invalid, forward the original completed pages 1 and 2 to the Records Administrator and perform steps 10 to 13 below. If considered valid, forward the original completed pages 1 and 2 to the Administrative Engineer and proceed to section 4.5, performing steps 4 through 10. 8. Review, sign and date the form. Forward the form to the Assistant Director - RSCAP. ASSISTANT DIRECTOR 9. Approve the determination and sign and date the form. Forward the form to the Records Administrator. RECORDS ADMINISTRATOR

10. Provide a copy of the completed page 2 of the Observation Record form to the Planning and Scheduling Engineer.
11. Provide a copy of pages 1 and 2 to the CSR Supervisor and the RPSR Supervisor. Provide copies to PCD if the observation had previously been determined to be valid and this is a revision.
12. File the completed original pages 1 and 2 per Section 5.

PLANNING & SCHEDULING ENGINEER

13. Enter into the DBMS file the result of the validity determination and the date of that determination from the provided copy of page 2 of the observation Record form, t

l 4.5 JLrocessino of a Discrepancy (valid observation) SUPERVISOR 1. Review the discrepancy, indicating review by signature. Forward to the Assistant Director - RSCAP. HUU UN17 (157 M i, I'

~ Commonwealth Edison Braidwood Nuclear Power Station PROCEDURE MlMBER kEVISION BCAP-06 10 PAGE 23 OF 25 ASSISTANT DIRECTOR 2. Review the discrepancy and indicate approval by signature on Exhibit A. 3. Forward the completed pages 1 and 2 of the Observation Record form to the Administrative Engineer. ADMINISTRATIVE ENGINEER 4. Request, by meno, the Superintendent-Project construction Department to issue an NCR referencing the discrepancy, and to provide BCAP with a copy of the NCR. Provide sufficient information to prepare an NCR per Reference 2.1, including a copy of the observation Record form, pages 1 and 2. Indicate on the copies that there is no page 3. The meno shall also request PCD to provide specific information, if any, that may affect the validity determination of the observation. 5. Provide a copy of Page 2 of the observation Record form to the Planning & Scheduling Engineer for recording of the validity determination result and file date in the DBMS Observation Record file. 6. Forward a copy of pages 1 and 2 of the discrepancy to the Supervisor for consideration in corrective action program .a evaluation in accordance with Reference 2.4, Section 4.5. 7. Provide a copy of Pages 1 and 2 to the CSR Supervisor and the RPSR Supervisor and the original completed Pages 1 and 2 to the Records Administrator. 8. If an NCR is issued, enter the NCR number, when received, into the DBMS file for that observation. PLANWING & SCHEDULING KAGINEER 9. Record result of validity determination and file date in the DBMS Otservation Record file. SUPERVISOR

10. Perform additional review per Section D, Review of Discrepancy / Concern Compilations.

11000831S (157M) I

O .s Commonwealth Edison Braidwood Nuclear Power Station PROCEDURE MNSER REVISION BCAP-06 10 PAGE 24 0F 25 D. REVIEW OF DISCREPANCY / CONCERN CottPILATIONS PLANNING & SCHEDULING ENGINEER 1. Monthly, or more frequently, generate computer-sorted listings of all. observations entered in the current DBMS file. Sort by BCAP element so as to list all valid observations. (discrepancies / concerns) 2. Provide sa copy of each sort to all Supervisors and BCAP-QA. 3. Generate additional sorts as requested by Supervisors. SUPERVISOR 4. Evaluate the lists and the associated discrepancies / concerns that have been processed through completion of Section A, B, or C as appropriate. Document the evaluation. Proceed as follows: a. CSR only:

1) Evaluate the listed discrepancies / concerns per Reference 2.7.
2) Evaluate the effect of RPSR concerns and RSCAP prograsmaatic discreparv es on the CSR activity, preparing a recommendat.cn, if applicable.

b. RPSP and RSCAP only: i

1) Evaluate the effect of C12 design-significant discrepancies and RPSR ccccerns or RSCAP programsatic discrepancies, as applica.ble, on the element activity under consideration, preparing a recommendation, if applicable.
2) Prepare activity results per Reference 2.8.

BCAP DIRECTOR 5. Review, for approval, reccumendations. 5.0 RECORDS 5.1 The records to be retained are the conpleted portions of Observation Record Form 06-1 and all attached pages. 110008319 l (1575J) en w

Commonwealth Edison Braidwood Nuclear Power Station PROCEDURE MNBER REVISION BCAP-06 10 PAGE 25 0F 25 5.2 The records will be filed in accordance with Reference 2.5. 6.0 004IBITS AND APPENDICES 6.1 Exhibit A - BCAP Forn 06-1, BCAP Observation Record. 6.2 Exhibit 5 - Sample Record of Observations. s 1 l 1 11000S320 (1575J)

.= _--- BCAP-06 EXHIBIT A Page 1 of 6 Revision 10 l BCAP OBSERVATION RECORD Page 1 of 3

1. OBSERVATION NO.

PART 1 OBSERVATION IDENTIFICATION & DESCRIPTION

2. DESCRIPTION OF ITEM (S&L dwg. number & revision if possible): 3. PACKAGE NO.
4. SYSTEM (if known):
5. CNBCKLIST/ ITEM NO.

. MM SWICE RM.

6. UNIT 1 l-l UNIT 2 l l

COf9 EON 0 l-l NO.

s. EunENT

,, 9.Oes e e m: , 7,,,,,,,,,,,,yg,, I._.I neinspection, Implementation x*'i'" l l CSR l l RPSR l l RSCAP OcMnmenta-i I et,,,,1,I I Other

10. DESCRIPTION OF OBSERVATION:

i

11. PREPARED BY:

Sienature Date PART 2 OBSERVATION CLARITY, COffLETENESS, AND ACCURACY REVIEN 12.CC sis / CLARIFICATION:

13. SUITABLE FOR FURTHER PROCESSING:

14.REVIENED BY: g g Sianature Date BCAP Forn 06-1 (Rev.10) l 110008321 (1575J) d m -,-.. - -w, ,.y- -.

i s BCAP-06 EXHIBIT A Page 2 of 6 Revision 10 BCAP OBSERVATION RECX)RD Page 2 of 3

15. OBSERVATION No.

PART 3 EVALUATION & DETERMINATION OF VALIDITY

16. EVALUATION
17. DETERMINATION OF VALIDITY:

IDE M l - l INVALID l - l SCOPE l l VALID 4 .hl 1 i

20. ARCHITECT / ENGINEER EVALUATION
18. EVALUATION & DETERMINATION I

ROQUIRED: l l YES l l NO Sianature Date

19. ACKNOWLEDGED BY:
21. REVIEWED BY:
22. APPROVED BY:

Signature Date l Sienature Datel Signature Date BCAP Forn 06-1 (Rev. 10) (15753) 110008322 i - - - -, - ~

.s BCAP-06 EXHIBIT A Page 3 of 6 Revision 10 BCAP OBSERVATION RECORD Page 3 of 3

23. OBSERVATION NO.

) PART 4 EVALUATION OF DISCREPANCY 26.

24. N/A l _ l Not Design Significant
25. EVALUATION (Include Comments on Root Cause):

l _ l Design Significant 1 (Attach additional sheets as necessary; do not write on reverse.) S & L Calc. #: 27. PREPARED BY:

28. APPROVED BY:

.tr S&L Signature Date S&L Signature Date PART 5 BCAP REVIEW 29.COIWiprFS, TRENDING, PROGRAM RECtPWEENDATION:

30. CONCUR WITH S&L DETERMINATION IN ITEM 24: YES l l

NO l l

31. REVIEWED BY:
32. ELEMENT SUPERVISOR:

Signature Date Signature Date l BCAP Form 06-1 (Rev. 10) 110008323 < 15.;u)

4 g BCAP-06 EXHIBIT A Page 4 of 6 Revision 10 Instructions for Observation Record Fora 06-1 Enter all of ths following information on each part of the form or N/A if not applicable. Part 1 Observation Identification and Description PREPARER 1. For CSE and RSCAP, enter a unique ntaber which consists of the package number and a sequential number. Por RPSR, use checklist number and a sequential number. For those CSR observations not related to specific packages, obtain a sequential observation number from the Inspecti6n Coordinator, who will maintain a log of such observations. In these cases, an XXX will be used in place of the package ntaber in the observation number. 2. Ites description: Enter a description of the equipment, material, component, procedure, e.g., bolts on Cire. Water Pump. Include the applicable drawing number (Sargent & Lundy) and revision if possible. 3. Package number: CSR - Enter Verification Package ntamber or "N/A" if not related to a package. RPSR - Not used; enter N/A. RSCAP - Program Ntaber per BCAP-60, Step 1.1. ' ;, 4. System in which ites is located; enter " unknown" if not known, or "N/A" if not applicable. 5. Checklist ntaber/ item number cross reference. If the population identifier is unknown, consult with the CSR Engineering Section to obtain a population number. 6. Check appropriate Unit: 0 Common to both units 1 Unit 1 only 2 Unit 2 only 7. List construction Support Service Request nsaber, if applicable, or enter N/A. 8. Check appropriate element. 9. Check whether observation was generated during reinspection, documentation review, procedure review, implementation review (RSCAP only), or through other means. 10. Description of Ot;servation. Include a sketch if necessary for clar*c,. Attach additional pages as necessary. Note the number of attachment pages, if any are used. 11000S324 g3,

e v e ~ BCAP-06 EXHIBIT A Page 5 of 6 Revision 10 11. Signature of the inspector, documentation reviewer, or engineer preparing the Observation Record. Date the form. For RPSR and RSCAP, enter N/A in all itant of Part 2. Part 2 Observation Clarity, Coggleteness and Accuracy Review (CSR only) LEAD DISCIPLINE INSPECICE or LEAD DISCIPLINE ENGINEER (if preparer is an engineer)

12. Cessents/ clarifications on observation.

13. Check whether observation is suitable for further processing. \\ 14. Signature and date as reviewer of observation Record. Part 3 Evaluation in Determination of validity LEAD DISCIPLINE ENGINEER - CSR SUPERVISOE OR DESIGNEE - EPSR, RSCAP 15. Enter the observation russber listed on Page 1 of the form. 16. Reviewer's evaluation of observation. Include specific justification for a determination that the observation is invalid. Include specific reason for a determination that the observation is outside BCAP scope. Attach pages as necessary. .a 17. Reviewer's determination of validity of observation or whether observation is outside BCAP scope. 18. Signature of evaluation and determination reviewer and date. PREPAREE (CR PREPARER'S SUPERVISION, IF MBCESSARY) 19. Signature and date acknowledging invalid determination only. (otherwise Lead Discipline Engineer or Supervisor enter "N/A".) ELEWrf SUPERVISOE (ASSISTAarf DIRECTCE if a disputed validity determination) 20. Enter determination of the need for Architect / Engineer evaluation of CSI documentation discrepancies. Enter NO for CSR observations outside BCAP scope. Enter YES for all C3R reinspection discrepancies. Enter ND for all EPSR and RSCAP discrepancies. 21. Reviewer's signature and date. Enter "N/A" in item 22 for an undisputed CSR observation. 110008325 (1575J) l _.m .,. ~ _ - -..... ... - - -. -. - - - - - -, - ~.. - - - - - -. -

f 4 g O BCAP-06 EXHIBIT A Page 6 of 6 Revision 10 DIRECTOR (required only for disputed observations) 22. Approval signature and date. Part 4 Evaluation of Discrepancy (CSR only) SARGENT & LUNDY 23. Enter observation maaber as listed on Page 1 of the form. 24. N/A 5

25. Evaluation of CSR discrepancy and, if design significant, provide comments on root cause. Attach additional sheets as necessary with specific reference to these sheets on page 3.

Include the supporting design calculation number, if appropriate.

26. Design-significance determination; check appropriate box.

27. Signature and date of preparer of evaluation.

28. Signature of A/E approver and date.

Part 5 BCAP Review (CSR only) i' LEAD DISCIPLINE ENGINEER 29. Enter any comments on the S&L evaluation. Attach pages as necessary. 30. Indicate YES or NO for concurrence with S&L determination in iteet 24,

31. Reviewer signature and date.

EIA ENT SUPERVISOR

32. Signature and date for closecut.

l i (15753) 11000S326 l r, w e 4mw,, ,-nn,m-w m o-4,we -v n- - p - v-e,, -p-,-w

l ( 4 p. O BCAP-06 EXHIBIT 8 Page 1 of 1 Revision 10 I !. l ..N. l l d, O

1 **i A.

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