Text

Applicant Exhibit A-135,consisting of Undated Conduit Support Reverification Program
	ML20214D870
Person / Time
Site:	Braidwood
Issue date:	10/08/1986
From:	; AFFILIATION NOT ASSIGNED
To:	;
References
	OL-A-135, NUDOCS 8705210518
	Download: ML20214D870 (130)
	v • d • e

_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____.

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CONDUIT SUPPORT REVERIFICATION PROGRAM ECLKETED USNHC TABLE OF CONTENTS

'87 APR 21 P7 55 j

I.

INTRODUCTION OFFIE L.5 9 n ia i II.

NUCLEAR REGULATORY COf9tISSION REPORT NO. 50-456/85-02(DRP ffdhC 50-457/85-02(DRP)

III. ERC OBSERVATION REPORT NO. BCAP-08S-011 IV.

BCAP RESPONSE AND CORRECTIVE ACTION FOR ERC OBSERVATION NO. BCAP-OBS-011 V.

SUMMATION 1

EXHIBIT A - BCAP MEMO #546 EXHIBIT B - BCAP MEMO #551 EXHIBIT C - JOINT SESSION TRAINING EXHIBIT D - REVERIFICATION PLAN EXHIBIT E - REVERIFICATION PLAN TRAINING EXHIBIT F - REVERIFICATION RESULTS EXHIBIT G - COMPLETED CHECKLISTS EXHIBIT H - OBSERVATIONS INITIATED EXHIBIT I - FEEDBACK TRAINING EXHIBIT J - CSR-I-E-COH REV. 4 CONDUIT HANGER CHECKLIST INSTRUCTION NUCLEAR REGULATORY COMM11510N Docket No.S-Yf 0 cial Enh. No.

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V Staff IDENTIFl[D Applicant M

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Intervenor REJECTED Cont'g Offt Contractor DATE

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SECTION I INTRODUCTION i

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Page 1 of 1 INTRODUCTION This report describes and documents actions executed by BCAP predicated upon concerns expressed by the Nuclear Regulatory Comunission (NRC) and the Independent Rxpert Overview Group (ISOG). Details of these concerns are addressed in NRC Report Nos. 50-456/85-02 (DRP), 50-457/85-02 (DRP) and IEOG ERC Observation Report No. BCAP-OBS-011 contained in Sections II and III respectively. Consequently all Construction Sample Reinspection (CSR) activities were suspended on January 23, 1985. A midpoint look was initiated to assess program effectiveness based on past experiences of CSR activities.

The assessment process identified specific attribute areas requiring further evaluation within the Electrical Conduit Support population. The Electrical Level III Inspector developed a reverification plan addressing the areas of concern and CSR' Electrical Inspection personnel were instructed accordingly.

All fifty-one (51) conduit support reinspection packages completed prior to January 24, 1985 were reinspected in accordance with the approved reverification plan. Specific action taken and results are addressed in the Sussnation contained in Section V and Exhibits A through J.

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SECTI0tt II NUCLEAR REGULATORY C00 MISSION (NRC)

REPORTS 50-456/85-02 (DRP) 50-457/85-02 (DRP) i 1

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FEB 13 885 w '~~ 7.,.

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a Docket No. 50-456-Docket No. 50-457 Comonwealth Edison Company.

ATTN: Mr. Cordell Reed Vice President' Post Office Box 767 Chicago, IL 60690 Gentlemen:

This refers to the special. safety inspection conducted by Mr. R. B. Landsman on December 13, 1984, andMr."R.N.'SardneronJanuari2'throughFebruary'1, 1985, of Braidwdod'Constrictior).Assessmertf Program (BCAP) activities at,.

Braidwood Nuclear Power Station,' Units l'and 2 authorized by. NRC {onstruction Per1 nits No. CPPR-132 and No. CPPR.133 and to the discussion of ou'r findings with Mr. L. Kline at the'conclusfon of the inspection.

The enclosed copy of our inspection rep' ort identifies areas examined during-

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the inspection. Within these areas, the inspect 1en. consisted-of-a selective examination of. procedures any' representative.-records, observations; and interviews with personnel. "

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'r-No items of. noncompliance with NRC;requipements..were-identified'during the course of this inspection. " -

4.

In accordance with 10 CFA 2.790(4), a copyrof.this ' letter.a.nd the. enclosure'-

will be placed in the NRC P.ublic; Document ~R6ca'valessiou notify this ~ office',

by telephone, within ten days 'iUthe?date'6f.-this"htter"and'.' submit. written -

applicatiort to withhold 4afsrimation conta'ifiid thergfri'Within thirty' days <of' the date of:this letter. Such application must~ be-consistent with:the '.. * -

requirements of 2.790(b)(1).

If two;do not, hear frosi,yedifn this t'egard.within -

the specified periods noted above :a c6py~of'tEis.16tter and the &nclosed ' ~

inspection report will be placed in the Public D6ddment; Room.

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FEB 131985

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We will gladly discuss any questions you have concerning this inspection.

Sincerely,

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-h R. F. Warnick, Chief Projects Branch 1

Enclosure:

Inspection Report No. 50-456/85-02 DRP ;

No. 50-457/85-02 DRP cc w/ enc 1:

D. L. Farrar, Director of Nuclear Licensing M. Wallace, Project Manager D. Shamblin, Construction

/ Superintendent C. W. Schroeder, Licensing and Compliance Superintendent DMS/ Document Control Desk (RIDS)

Resident Inspector. RIII Braidwood Resident Inspector, RIII Byron Phyllis Dunton, Attorney General's Office Environmental Control Division D. W. Cassel, Jr., Esq.

E. Chang, ELD J. Stevens, LPM

c.

k U.S. NUCLEAR REGULATORY COMMISSION REGION III Reports No. 50-456/85-02(DRP);50-457/85-02(DRP)

Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Nuclear Power Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, Illinois Inspection Conducted: January 2 through February 1,1985 Inspectors:

R. N. Gardner R. B. Landsman I4 h L "

Approved By:

W. Forney, ef J/A2/P[

Projects Section IA Date' Inspection Summary Inspection on January 2 through February 1,1985 (Reports No. 50-456/85-02(DRP);

50-457/85-02(DRP))

Areas Inspected: Special, announced safety inspection of the Braidwood Con-struction Assessment Program (BCAP) in regards to licensee action on previously identified items Construction Sample Reinspection (CSR) Reinspection Checklists, CSR Documentation Review Checklists S&L evaluation of BCAP discrepancies, CSR reinspction activities, and Review of Procedures to Specification Requirements (RPSR) activities. The inspection consisted of 165 inspector-hours ensite by two NhC inspectors.

Results: No items of noncompliance or deviations were identified.

DETAILS l

1.

Persons Contacted Commonwealth Edison Company (CECO)-

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L. DelGeorge, Assistant Vice President

T. Maiman, Manager of Projects

M. Wallace, Project Manager

- E. Fitzpatrick, Assistant Quality Assurance Manager

J. Deress, Byron and Braidwood Projects Engineering Manager

B. Shelton, Projects Engineering Manager

- N. Kaushal, BCAP Director

C. Schroeder, Project Licensing and Compliance

'L. Kline, Project Licensing and Compliance

'N. Smith, BCAP Quality Assurance Supervisor

D. Shamblin, Project Construction Superintendent

R. Byers, BCAP Assistant Director

D. Farrar, Nuclear Licensing

I. Johnson, Nuclear Communications Coordinator

P. Lau, Quality Assurance Engineer

G. Orlov, BCAP Assistant Director

A. Scaccia, Offsite Emergency Planner

D. Smith, Nuclear Licensing Administrator Daniel Construction Company M. Clinton, BCAP Inspection Supervisor E. Shevlin, BCAP Lead Inspector Stone and Webster Engineering Company (S&L)

V. Hoffman, Site Manager i

W. Willoughby, BCAP Technical Assistant Sargent and Lundy Engineers (S&L)

D. Leone, Projects Director Evaluation Research Corporation (ERC)

J. Hansel, Project Manager

R. Ham, Assistant Project Manager

W. Chase, Consultant Illirois Department of Nuclear Safety

R. Minue, Nuclear Engineer 2

l Illinois Commerce Commission

L. Ferguson, Utility Engineer

J. Mcdonald, Utility Engineer Isham. Lincoln and Beale l

R. Lauer, Attorney Other

D. Cassel, BPI, Attorney The inspector also contacted and interviewed other licensee and contractor personnel during the course of this inspection.

Denotes those present at the January 3,1985 public meeting on BCAP.

Denotes those present at exit interview.

2.

Licensee Action on Previously Identified Items (0 pen) Open Item (50-456/84-32-01; 50-457/84-30-01): BCAP inspectors were determining the acceptability of the elevation and location of installed components by utilizing chalk-marks which were handwritten on 4

plant structures. On January 8, 1985, the inspector attended a training session which was held to provide BCAP inspectors with direction in the use of approved survey marks for BCAP reinspections. The BCAP inspectors were provided with a handout which illustrated approved survey marks.

During the training session the BCAP inspectors stated that during previous reinspections the method of dealing with inspection attributes requiring valid survey marks for which the marks were non-existent or were of questionable origin was to N/A the attribute. Subsequent to this training session, the inspector informed the licensee that inspection attributes previously documented as N/A due to the lack of adequate survey marks would require the installation of such survey marks as necessary to allow the completion of the reinspection. This item will remain open until the inspector has verified that required reinspections are com-pleted.

3.

Review of CSR Reinspection Checklists 4

The inspector reviewed the BCAP reinspection checklist for concrete placements delineated in document CSR-I-S-001, approved November 8, 1984 The inspector determined that the checklist was inadequate because it does not address important concrete attributes such as cracking and patch quality. The licensee indicated that the checklist was only meant to address major design deficiencies and not individual discrepancies.

In order for a concrete reinspection program to adequately reflect the quality of concrete it should include clearly definitive accept / reject

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criteria for all concrete attributes.

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Additionally, the deletion of the inspection of embedded plates on the non-Q turbine building side of the O L-line wall as the corrective action taken to ERC observation BCAP-0BS-003 is unacceptable. The licensee i

indicated that any non-Q attachments to that side of the wall would not jeopardize the integrity of the wall. Any attachments to a solid concrete wall, whether Q or not-Q, will affect the structural integrity of the wall.

Therefore, both sides of that wall should be inspected for all attributes.

In sunmary, the concrete placement reinspection will not be able to i

detemine whether the concrete placed at Braidwood is acceptable. This item remains open pending the licensee's response (50-456/85-02-05; 50-457/85-02-05).

Furthemore, even though it is outside of the BCAP reinspection, the inspector identified a concern with the site concrete palching procedure.

4

" Concrete Finishes Curing and Protection," Revision 8, dated October 23, 1984. Paragraphs 4.5 and 4.6 are inadequate in that irportant patching attributes such as the initial preparation of the exiscing concrete surface, the material to be used for the patch, the m thod of placing the material and curing of the patch are not addressed. This resulted in the patch for NCR number 213-544 in the auxiliary building appearing to be unacceptable. This item remains open pending the licensee's review (50-456/

85-02-06;50-457/85-02-06).

4.

Review of CSR Documentation Review Checklists The inspector reviewed the documentation review checklist for population AWS DI.1, Electrical Welds. During this review'the inspector observed that the BCAP checklist instructions stated that the acceptable certifica-tion level for L. K. Comstock electrical weld inspectors who inspected and accepted welds was a minimum of Level I.

This does not meet the require-ments of ANSI N45.2.6 which requires, as a minimum, a Level II certifica-l tion for inspection personnel who inspect and accept construction activi-l ties. BCAP personnel had previously informed the inspector that the BCAP program had identified a concern with the use of Level I inspectors during past onsite inspection activities. The licensee stated that an observa-tion would be issued to document this matter. Pending a review of the observation and its subsequent disposition, this is an open item (50-456/

85-02-01;50-457/85-02-01).

The inspector subsequently reviewed L. K. Comstock Weld Inspection proced-ure 4.8.3, revision F, dated May 10, 1984, and revision G dated December 7, 1984. Revision F to the subject procedure allowed a Level I or Level II inspector to perform weld inspections and determine acceptability of the inspected welds. Revision G now requires a Level II inspector to perform weld inspections. This matter was discussed with the Senior Resident Inspector and is being tracked as an unresolved item in NRC Inspection Report Nos. 50-456/84-42 and 50-457/84-38.

4

9 5.

Review of S&L Evaluation of BCAP Discrepancies BCAP observations which are deemed valid by BCAP CSR engineering are called discrepancies and are forwarded to S&L for additional validity review and evaluation of design significance. Upon completion of the S&L review and evaluation, the discrepancies are returned to BCAP for review and concurrence.

- The inspector reviewed 42 mechanical discrepancies 39 electrical discrep-ancies,25 Heating, Ventilating..andAirConditioning(HVAC)discrep-ancies, and 17 civil discrepancies. The discrepancies had been reviewed and evaluated by S&L and returned to BCAP. BCAP CSR engineers had not reviewed and concurred in the returnec' discrepancies. The review focused on the S&L validation and evaluation of the BCAP discrepancies. During the review the inspector detemined the following:

i a.

Over 60 percent of the electrical observations identified as valid discrepancies by the BCAP CSR engineers were identified as invalid discrepancies by S&L.

'l b.

The documented basis for the invalidation of certain discrepancies by S&L did not support the invalidation. This is exemplified by the following examples:

(1) Discrepancy number CSR-I-E-CND-012-01 identified conduit CIA 2251 as not being attached to conduit hanger CC50. This discrepancy was invalidated on the basis that an Avoid Verbal Orders (AVO) document, identified as AV0-03397, had instructed the electrical contractor to remove the hanger. S&L further stated that the contractor would subsequently be instructed to reinstall the hanger. The inspector detemined that an AVO is not a controlled document and the use of AV0's has resulted in the issuance of generic nonconfomance report number 1996.

Therefore, an AVO cannot be considered as an acceptable basis l

for invalidating a discrepancy.

l (2) Discrepancy number CSR-I-E-CND-037-01 identified a cable bushing which fell off when touched by the BCAP inspector. S&L l

invalidated this discrepancy on the basis that the bushing did not fall off until touched and therefore was in place during cable installations. This is not an acceptable basis for invalidation since there is no assurance that the bushing had not fallen off earlier during cable installation activities.

(3) Discrepancy number CSR-I-E-CND-042-01 identified loose flex fittings on the conduit where the conduit was attached to equipment. A cable had been pulled through the conduit and terminated, however, the cable termination had not been l

inspected. S&L invalidated this discrepancy based on their position that Quality Control (QC) inspectors who inspect cable terminations will inspect for loose flex fittings. The 1

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inspector reviewed the QC inspection procedure for cable terminations and was unable to ascertain where the purported flex fitting inspection was delineated in the procedure.

The inspector discussed the adequacy of the S&L discrepancy review and evaluation with the licensee. This is an unresolved item (50-456/85-02-02;50-457/85-02-02).

6.

CSR Reinspection Activities a.

On January 16, 1985, the inspector witnessed the overinspection of a concrete placement. The overinspection was being performed by an Evaluation Research Corporation (ERC) inspector. The concrete placement had previously been reinspected by the BCAP taskforce.

The reinspection package was numbered CSR-1-S-01-120. During the overinspection, the following was observed:

(1) An embedded plate was observed which had a visible partial identification number which did not match the vendor drawing for that plate.. This embedded plate was not identified as an observation by BCAP inspectors.

(2) Two construction joints were observed which did not appear on design drawings. These construction joints were not identified as observations by BCAP inspectors.

(3) An embedded plate was observed which had no visible identification numbers. The plate was accepted by BCAP inspectors.

(4) Two embedded plates were observed which had visible identification numbers which were identified as not verifiable by BCAP inspectors.

The above reinspection deficiencies were subsequently documented in ERC observation 010.

b.

On January 23, 1985, the inspector, accompanied by'an ERC inspector, performed an overinspection of electrical conduit hanger CC-125.

The hanger was previously reinspected by the BCAP taskforce. The reinspection package was numbered CSR-I-E-COH-20. During the overinspection, the following was observed:

(1) A conduit supported by the conduit hanger was not the conduit identified on the pertinent S&L drawing. This was not identified by the 8 CAP inspector.

(2) Two attributes on the reinspection checklist were documented as N/A by the BCAP inspector. These attributes were applicable and should have been reinspected.

1 1

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(3) One attribute was documented as accepted by the BCAP inspector

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which was not applicable to the hanger. This attribute should have been documented as N/A.

The above reinspection deficiencies were subsequently documented in ERC observation 011.

c.

On January 23, 1985, the inspector, accompanied by an ERC inspector, perfomed an overinspection of electrical conduit hanger CC-512.

The hanger was previously reinspected by the BCAP taskforce. The reinspection package was numbered CSR-1-E-COH-12. During the overinspection, the following was observed:

(1) One attribute on the reinspection checklist was documented as N/A by the BCAP inspector. This attribute was applicable and should have been reinspected.

(2) Two attributes on the reinspection checklist were documented as acceptable by the BCAP inspector which were not applicable to the subject hanger. These attributes should have been documented as N/A.

(3) Required back-plates for the subject hanger were not installed.

This was not identified by the BCAP inspector.

The above reinspection deficiencies were subsequently documented in ERC observation 011.

The aforementioned overinspections of electrical conduit hangers and the overinspection of the concrete placement created a concern that BCAP reinspections were not adequately identifying construction deficiencies.

This concern was reinforced by the Construction Appraisal Team (CAT) findings regarding BCAP reinspection deficiencies in the area of mechanical pipe supports.

l l

On January 23, 1985, the inspector met with the BCAP Director to discuss the need for significant actions to address the issue of BCAP i

reinspection deficiencies. Subsequent to that discussion the licensee issued BCAP memorandum f546 implementing a midpoint look into the CSR reinspection program. Reinspections were suspended until written authorization was provided to allow resumption. As a result of the identified reinspection deficiencies, the licensee has initiated a program which involves the partial repeat reinspection of 160 previously reinspected mechanical pipe supports, the assessment of the need to repeat reinspections in other BCAP populations, the assessment of additional training requirements, and the assessment of the need to revise reinspection checklists and instructions. Pending a review of the licensee's actions to resolve BCAP reinspection deficiencies, this is an unresolved item (50-456/85-02-03; 50-457/85-02-03).

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7.

Review of RPSR Activities Initial procedure verifications were initiated on January 31, 1985. The BCAP taskforce had experienced considerable delays in the initiation of the RPSR BCAP element due, in large part, to difficulties encountered in the development of procedure checklists. As this BCAP element will consist of a review of all on-site contractors' installation and l

inspection procedures for ongoing and future safety-related construction activities as of June 30, 1984, some considerations as to the effects of the delay on the results of the program are in need of assessment.

RPSR was to review " current" installation and inspection procedures.

a.

30, 1984, there have been numerous procedure revisions Since June which means that current installation and inspection procedures will not be reviewed.

b.

Procedures were to be verified for compliance to specification requirements in effect as of June 30, 1984. Since that date numerous specification changes have taken place which will not be used in the RPSR review. Additionally, the spec changes will not be reviewed for conformance to FSAR requirements.

Pending a resolution to the above RPSR concerns, this is an open item (50-456/85-02-04;50-457/85-02-04).

8.

Public Meeting to Discuss BCAP The January public BCAP status meeting was held on January 3,1985, at the Mazon Emergency Offsite Facility (EOF). Participants in the meeting included Messrs. B. Davis, E. Greenman, W. Forney, and R. Gardner of the NRC staff, M. Wallace, N. Kaushal, and N. Smith of Ceco, K. Kostal of S&L and R. Ham of ERC.

Subjects addressed during the meeting included a presentation on the status of BCAP activities, a summary of the S&L review of discrepancies identified to date, the BCAP QA overinspection program, and the status of ERC reviews and observations identified to date.

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9.

Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraphs 3, 4 and 7.

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10. Unresolved items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items disclosed during the inspection are discussed in Paragraphs 5 and 6.

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11. Exit Interview The inspector met with licensee representatives (denoted under Persons Contacted) during and at the conclusion of the inspection on February 5, 1985. The inspector sumarized the scope and findings of the inspection.

Attachments:

1.

Memorandum from C. E. Norelius to J. G. Kappler dtd 1/22/85 2.

Ltr from Ceco to J. G. Keppler dtd 1/15/85 3.

Memorandum from P. R. Pelke to RIII Files dtd 2/07/85 9

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SECTION III ERC OBSERVATION REPORT BCAP-OBS-011 9

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AWf o c S;; l 3',3 y

FIELD OPERATIONS

.L WMMM 800 Oak Ridge Tumpake WESEAWCM sut. soi COWPOWATION o.k ado.Tenn 37ssi (615) 442-7073 January 23, 1985 BCAP-132 Commonwealth Edison Company Braidwoct Station R.R. #1, Box 81 Braceville, IL.

60407 ATTENTION:

Mr.

N. Kaushal

SUBJECT:

ERC Observation Report BCAP-0BS-Oll Gentlemen:

Enclosed is ERC Observation Report No. BCAP-0BS-Oll.

Please respond to,the observation identified on the report form and return your response by February 13, 1985.

Yours very truly, John L. Hansel Project M V W Y anager */so/gf

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JLH:REH:PLC:CMT/jlt cc:

T. Maiman7 R. L. Byers N. Smith IE0G Team (2) Files R. N. Gardner J. G. Keppler l

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TESEATCH OBSERVATION REPORT l

COTPOWATION Observation No. BCAP-0BS-Oll Date January 29, 1985 To:

N. Kaushal From: ERC Project Manager BCAP Director iE NOns tl 30/ 8f Signatu re Date observation: The results of overinspection of reinspection Verification Package No.'s CSR-I-E-C0H-03, -12 and -20 indicates that the inspector had incorrectly dispositioned attributes for inspection on the Reinspection Checklist.

1.

For CSR-I-E-C0H-03:

a.

Attributes 3d. Internal Connections: Gusset Plate and 3f. Internal connections: Welds were documented on the checklist as being accepted. The attributes are not applicable to this hanger config-uration.

Signature of Orignator Date

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8 CAP Director Date Respcase is A c:ptable Un:::ept:ble RCA No.

Issued Signature Date i

ERC Project Manager QF-15.1.1 8/84 Page 1 of 2 i

BCAP-0BS-011 Page 2 of 2 Y

b. Attributes 2f. Gap between Auxiliary Steel and Structural Steel and 4c. Base Plate were documented on the checklist as being N/A. The attributes are applicable to this hanger configuration.

2.

For CSR-I-E-C0H-12 (Conduit Hanger No. CC-512-0-3312-A)

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a. Attribute 2f. Gap between Auxiliary Steel and Structural Steel was documented on the checklist as being N/A.

The attribute is applicable to this hanger configuration.

b. Attributes 3f. Internal Connections: Welds and 3. Internal 9

Connections: Bolting was documented on the checklist as being accepted. The attributes are not applicable to this hanger configuration.

c.

S & L Drawing No. 20E-0-3312C07 Rev. AF instructs the use of 1" back plates for Hanger No. CC-512.

"As found" conditions in the field indicates that no one-inch back plates were used. This discrepancy was not documented by the inspector.

3.

For CSR-I-E-C0H-20 (Conduit Hanger No. CC-125-0-3311A):

a. Attributes 2f. Gap between Auxiliary Steel and Structural Steel and 4c. Base Plate were documented on the checklist as being N/A.

The attributes are applicable to this hanger configuration.

Attribute 3. Internal Connections:

b.

9 Bolting was documented on the checklist as being accepted; the attribute is N/A to this hanger configuration.

c. Attribute 7. Wireway / Conduit Installation:

S & L Drawing No. 20E-0-3311C02 indicates conduits F6 and F9 are attached to conduit support No. CC-125.

"As found" conditions conduit F6 and F4 are attached to conduit support No. CC-125.

There is a conflict between S & L drawing and "as found" field conditions. This discrepancy was not documented by the inspector.

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SECTION IV BCAP CSR RESPONSE / CORRECTIVE ACTION TO ERC OBSERVATION NO. BCAP-OBS-011 f

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FIELD OPERATIONS t

WMATION soo oak niege Turno we WEBEAWCH su:te sos COWPOWATION Oak Ridge. Tennessee 37830 )

(615) 482-7973 February 21, 1985

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Commonwealth Edison Company Braidwood Station l

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1, Box 81 Braceville, IL.

60407 ATTENTION:

Mr.

N. N. Kaushal

SUBJECT:

ERC Observation Report BCAP-0BS-Oll Gentlemen:

Enclosed is the subject Observation Report indicating ERC's acceptance of the BCAP resonse dated February 21, 1985.

This observation is considered closed.

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Yours very truly, John L. Hansel Project Manager Enclosure JLH:WLC:CMT/dit cc:

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R. L. Byers N. Smith IE0G Team I

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EVALUATION 6-TESEATCH CORPOWATIO,N OBSERVATION REPORT g-or Observation No. BCAD-0BS-011 Date January 29, 1985 To:

N. Kaushal From:

ERC Project Manager BCAP Director 9 E r'b J h u u f t/ 30/ a f-Signatu re Date Observation:. The results of overinspection of reinspection Verification Package No,'s CSR-I-E-C0H-03, -12 and -20 indicates that the inspector had

. incorrectly dispositioned attributes for inspection on the Reinspection Checklist.

i' 1.

For CSR-I-E-C0H-03:

a.

Attributes 3d. Internal Connections: Gusset Plate and 3f. Internal connections: Welds were documented on the checklist as being accepted. The attributes are not applicable to this hanger config-i uration.

Signature of Orignator Date

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b.

Attributer 2f. Gap between Auxiliary Steel and Structural Steel and 4c. Base Plate were documented on the checklist as being N/A.

The attributes are applicable to this hanger configuration.

2.

For CSR-I-E-C0H-12 (Conduit Hanger No. CC-512-0-3312-A)

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a. Attribute 2f. Gap between Auxiliary Steel and Structural Steel was documented on the checklist as being N/A.

The attribute is applicable to this hanger configuration, b.

Attributes 3f. Internal Connections: Welds and 3. Internal 9

Connections: Bolting was documented on the checklist as being accepted. The attributes are not applicable to this hanger configuration, c.

S & L Drawing No. 20E-0-3312C07 Rev. AF instru ts the use of 1" back plates for Hanger No. CC-512.

"As found"_ conditions in the field indicates that no one-inch back plates were used. This discrepancy was not documented by the inspector.

3.

For CSR-I-E-C0H-20 (Conduit Hanger No. CC-125-0-3311A):

a.

Attributes 2f. Gap between Auxiliary Steel and Structural Steel and 4'. Base Plate were documented on the checklist as being N/A.

c

,The attributes are applicable to this hanger configuration.

b.

Attribute 3g. Internal Connections:

Bolting was documented on the checklist as being accepted; the attribute is N/A to this hanger configuration.

c. Attribute 7. Wireway / Conduit Installation:

S & L Drawing No. 20E 0-3311C02 indicates conduits F6 and F9 are attached to conduit support No. CC-125.

"As found" conditions conduit F6 and F4 are attached to conduit support No. CC-125.

There is a conflict between S & L drawing and "as found" field conditions. This discrepancy was not documented by the inspector.

Attachmsnt to j,

BCAP-OBS-011

\\

RESPONSE / CORRECTIVE ACTION The three ERC Observations in BCAP-OBS-011 were verified as being generally correct. Actions to determine the extent of inappropriate checklist entries and to evaluate the impact on the completed reinspections have been completed.

Prior to performing these actions, a joint instruction / training session with CSR Engineering / Inspection personnel was held to ensure a thorough understanding of the ERC Observations and the proper interpretation and application of the checklist instructions for the affected attributes.

As a result of these discussions the checklist instruction for Attribute number 7 was revised and attributes were identified on which misunderstanding might have existed.

All fifty one conduit support packages completed prior to January 24, 1985 were reviewed and reinspected where necessary. Based on these reviews and reinspections, appropriate corrections / changes to the package documentation have been completed. A second feedback instruction /

training session was held on February 8, 1985 to disseminate the svaluation and review results to affected inspection and appropriate management personnel.

Reinspections of conduit supports resumed on February 8, 1985.

f Y'b-A -M-9'S 0982J

t 4

C Iv SBCTION V SUMMATION (167Q) l l

page 1 of 3 SUDORTION t

-l Since the NRC Reports identified their concerns as unresolved items and referenced IBOG/ERC Observation Report No. BCAP-OBS-011 this report primarily l

is, directed toward the concerns addressed in the observation report.

i On January 23, 1985 CSR Blectrical Inspection activities were suspended as directed in BCAP Meno #546, Exhibit "A."

Initial steps to address the above concerns began on January 24, 1985 via BCAP Memo #551, Exhibit B, and are susmarized as follows:

a) Areas of agreement / disagreement associated with inspection requirements and use of design documentation were identified.

'b)

Areas of disagreement were resolved.

c) The need for verification of reinspections completed prior to January 24, 1985 were assessed.

t Actions taken and results achieved are as follows:

1.

In accordance with Exhibit "B" a joint session was conducted between BCAP CSR Electrical Inspectors and CSR Electrical Engineers on January 30, 1985 to discuss and provide clarification, (as necessary) for the attribute instructions contained in the conduit Hanger Checklist Instruction No.

CSR-I-E-COH Rev. 3.

The primary objective of the session was to assure that Inspectors fully understood the instructions for proper implementation of reinspection of the conduit Hanger / Support population.

Specific areas of concern were identified similar in nature to the concerns identified in the ERC observation report. Seven (7) attribute 4

areas were identified as requiring clarification to the Inspectors and the need for a reverification of these attributes on all packages completed prior to January 24, 1985. A followup session was held on January 31, 1985 resulting in a revision to Attribute 7 of the Checklist Instruction to provide more clearly defined instructions. The revised Checklist Instruction No. CSR-I-E-COH Rev. 4 is enclosed as Exhibit "J 2.

A Reverification Plan was developed by the Electrical Level III Inspector and approved by the BCAP CSR Inspection Supervisor on February 1, 1985.

All fifty-one (51) Conduit Support Packages completed prior to January 24, 1985 were included within the scope of the plan for review and j

reinspection where necessary. During the development of the plan and additional assessment of the ERC attribute concerns, Attribute 31

)

applicable to Detail "J" on Drawing 20E-0-3393F was excluded from the scope of the reverification and substituted with Attribute 31 for the following reasons:

Attribute 31 pertained to only three (3) of the fifty-one (51) a.

packages. One (1) of the three (3) packages CSR-I-E-COH-12 was identified in the ERC Observation. CSR Observation Report (1676J)

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

f,-

_(

Page 2 of 3 CSR-I-E-COH-12-03 was initiated to correct the deficiency. The two (2) other packages, CSR-I-E-COH-21 and CSR-I-E-COH-41 were satisfactorily inspected during the original reinspection effort, therefore it was concluded that no further deficiencies existed in this attribute area.

t b.

Minor concerns were expressed in Attribute 3.1 therefore considerations were given this attribute area and included in the l

reverification plan checklist.

The Reverification Plan is comprised of definitive actions to be executed and a special checklist containing specific instructions for reverification of each of the seven attribute areas of interest. A copy of the Reverification Plan is enclosed as Exhibit "D."

3.

Two training sessions were provided. Exhibit "C" documents the sessions between CSR Electrical Inspectors and CSR Electrical Engineering as delineated in BCAP Memo #551, Exhibit "B."

Exhibit "E" documents the training provided prior to implementation of the reverification plan.

Inspectors were instructed in the objectives outlined in the plan, the attributes to be reverified and the special instructions applicable to each of these attributes.

4.

Control measures were established to preclude Electrical Inspectors from reverifying their own previously performed inspections. The completed checklists enclosed as Exhibit "G"

lists the original inspector and the inspector who performed the reverification inspection.

5.

The actions taken associated with the reverification are detailed in Exhibit "D" and summarized as follows:

Conduit Hanger Reinspection packages were reviewed for characteristics of specific attributes of concern.

A review of hardware design requirements versus installation configuration was performed.

Comparison of review results were tabulated.

Evaluation of tabulation was performed by Electrical Level III Inspector.

Corrective action, where appreciate, were taken.

6.

Observations initiated during reverification were processed in accordance with BCAP Procedure BCAP-06.

All new observations initiated during the reverification were incorporated into the appropriate Reinspection Package.

NOTE: During the reverification all new observations were determined by the BCAP Electrical Level III to be correct.

Observations written as a result of this plan are enclosed as Exhibit "H."

(16'76J)

.t c-Page 3 of 3 7.

Feedback / training was provided each inspector to communicate the result of the reverification plan. The feedback / training attendance roster is enclosed as Exhibit "I."

C0$CLUSION The Conduit Support Reverification Program contained three hundred fifty-seven (357) attributes of which fifty-three (53) were identified to be inappropriate entries as follows:

1.

Thirty-seven (37) were recorded as inspected and should have been recorded as N/A.

2.

Ten (10) recorded as U/A required inspection and were reverified to be acceptable.

3.

Two (2) recorded as N/A required inspection and was reverified as rejectable.

4.

Four (4) were recorded as acceptable and reverified as rejectable.

5.

One (1) originally rejected attribute required an additional observation as a result of the revised instruction for Attribute No. 7.;

similarity between attributes on the checklist resulted in inspector confusion relative to specific attribute applicability to hardware, therefore forty-seven (47) of the items originally recorded as N/A were inspected and documented on non-applicable attributes.

Seven (7) new observation reports were initiated upon completion of field inspections.

Five (5) % servations were written on Attribute No. 7 which would not have been written using the previous revision of the checklist i

instruction.

One (1) observation was written on Attribute No. 3d for undersize base plate on internal connections and one (1) on uninstalled base l

plates which were omissions during the original inspection.

Upon completion of the conduit Support Reverification Program the results were communicated to the Electrical Inspection personnel. The results of the sessions and lessons learned indicate the inspectors are confident they have a thorough understanding of the inspection checklist requirements.

No significant conditions adverse to quality were identified as a result of the reverification plan.

Reinspection on conduit supports resumed on February 8, 1985.

l (1676J) l

- - - - - - - - - - - - - - - - - - - - - - - ~~

1 January 23, 1985 BCAP Memo #546 l

TO:

R.

L.

Byers G.

M.

Orlov M. A.

Clinton FROM:

N.

Kaushal Over the last few days I have received input from several individuals that leads me to believe that it would be a good idea to do a midpoint look into the CSR activity.

During this process we will factor in the knowledge and ideas which have come forth from our experience in the process to date.

I would like us to not proceed any further with the inspection phase, except as specified by me in writing, until we have completed this midpoint look at the CSR activity.

$. lN,

"M N.

N. Kaushal BCAP Director NNK/sjs BCAP File QG 69.60.3 /

cc:

N.

P.. Smith, Q.A.

M. Wallace l

I l

f

~~

.,,v:

l, January 24, 1985 BCAP Memo #551 TO:

R.

L.

Byers G. M. Orlov M.

A. Clinton FROM:

N.

N. Kaushal This is a follow up to my Memo #546 dated January 23, 1985.

Based on my assessment of the situation I have concluded that we should proceed as follows:

We can proceed with the inspections or. reviews in all areas that I have previously given the release to do so except in the area of concrete placement, pip.i ng hangers / supports, and electrical hangers and supports.

In the area of piping hangers / supports, we should expeditiously conclude the reinspection verification effort that we initiated last Friday.

This verification effort pertains to reinspection of certain configuration-related attributes on all hangers / supports on which inspections were completed as of January 18, 1985.

Upon completion of this verification effort, we should assess the results and determine if any additional uraining of the inspectors in that area is necessary.

In any case the results of this verification effort should be fed-back to our inspection group.

Following completion of this feedback or training to the inspection group, further inspections in the piping supports /

hangers area may resume.

In the electri-al hangers / supports areas, we should hold a combined session between the electrical inspection group and individuals from the BCAP electrical engineering group to insure that the inspectors have a clear understanding of the inspection requirements and the use of the design documentation l

from which these inspection requirements are to be obtained.

Following this session, I would like to be briefed on the results.

If the results indicate that the inspectors are confident that they have a clear understanding of the inspection requirements, the inspections in the area of electrical hangers / supports will be allowed to proceed on my specific approval.

A decision on the need for verification of reinspection work already completed in this area will be made based on an evaluation of the results from this joint session.

l

I o

a Y

January 24, 1985 BCAP Memo #551 Page 2 Similarly in the civil / structural area, prior to proceeding with a new population such as the masonry walls, we should hold a joint session between the civil / structural inspection group and the civil / structural BCAP engineering group to assure that there is a clear understanding of the inspection requirements and the design documentation in the package from which these inspection requirements are to be obtained.

If after this session the inspectors indicate confidence they have a clear understanding of the inspection require-ments, the inspection in the new population may proceed.

However, inasmuch as we have to carry out inspections on some additional attributes in the concrete placements. area, we should not proceed with any further inspections in that population until we have fully reassessed the situation.

Please make sure that the results of the verification program, training sessions and any outcome of the joint sessions including any specific actions committed and lessons learnt are documented and retained.

N-N.

N. Kaushal, BCAP Director NNK/sjs cc:

BCAP File QG 69.60.3p' Mik; Wallace N.

P.

Smith, QA bcap20

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Page 1 of 3 h

REVERIFICATION PLAN ELECTRICAL CONDUIT HANGERS 1.

All Conduit Hanger Reinspection packages accepted prior to January 24,

.1985 shall be re-reviewed by BCAP Electrical Inspection for characteristics with specific attributes noted in ERC concerns.

Re-review shall consist of a comparison of hardware design configuration versus the configuration indicated by acceptance / rejection or N/A of the Reinspection Checklist attributes. All attributes recorded contrary to the design documents shall be noted on the BCAP Reverification Checklists.

Inspection attributes outside the scope of the ERC concerns are not addressed in this plan.

I 2.

The BCAP Reverification Checklists to record the reverification of the characteristics, identical to the areas of concern, are to be developed by the BCAP Electrical Level III Inspector and approved by the Inspection Supervisor.

3.

Inspectors performing the reverification are to be provided with instructions to assure complete and uniform understanding of the attribute areas to be reverified. Specific instructions on the use of the Reverification Checklist and applicable CSR Instruction will be provided and documented for record.

4.

The inspector performing the reverification shall not be the inspector who performed the initial reinspection.

5.

Results of the re-review of the reinspection packages, recorded on BCAP Reverification Checklists, will be evaluated by the BCAP Electrical Level III Inspector and corrective action assignments made. Attributes determined to be erroneously recorded as N/A shall be reverified by field inspection of the hardware. Results of the field inspection will be recorded on the BCAP Reverification Checklist and the CSR Reinspection checklist corrected accordingly. Attributes determined to be erroneously accepted rather than N/A shall be corrected after evaluation by the Level III Inspector. Attributes which, after package review, are indeterminate as to what the correct checklist entry should be shall be reverified by field inspection.

6.

Where an observation is made during reverification which was not made during the initial reinspection, a Certified Lead Quality Inspector (Electrical) will re-examine the subject characteristic to determine the validity of the new observation. If valid, the new observation will be processed in accordance with BCAP procedures. If the new observation is determined to be invalid, the reverification inspector will be shown, to his satisfaction, the reason for this determination of invalidity. The reverification inspector's acknowledgement of invalidity will be documented on the Reverification Checklist and the Observation Record.

Contested new observations will be processed in accordance with BCAP procedures.

0876J

BCAF Me.c =616 Piga 2 of 3 (v

REVERIPICATION PLAN ELECTRICAL CONDUIT HANGERS 7.

Results of the reverification will be evaluated to determine appropriate corrective actions. CSR Checklist Instructions shall be revised per applicable BCAP procedure, if lack of instruction or clarity of instruction is indicated. Appropriate instruction or training will be developed, submitted to BCAP management for approval, and presented to the inspectors should lack of training be indicated.

8.

Documents controlled by BCAP procedures, initiated or corrected as a result of this plan will be processed and retained in accordance with applicable procedures.

9.

Checklists, training instructions, notes or other documents initiated as a result of this plan but not controlled by BCAP procedures will be processed and retained as directed by BCAP Management.

Attachments:

Checklist - Reverification of CSR Conduit Hanger Reinspection.

i j

08'16J

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

sm :.

BCAP Mer-

616 l

REVERIFICATION OFCSR CONDUIT HANGER REINSPECTION

^3M"Ai' CSR PACKEE NUMBER:CSR-I-E-COH-SUPRET NUMBER:

ATTRI8tRE SPECIAL INSTRUCTIONS INSRBTAMTE RGER.87/04TE 00CLMNTfD AS REVERIFIED _AS ACTION TAKEN-N EIWEN REVIEN REIR$PElionW CtKCKLIST. RECDnD AUL STEEL DOCIMENTED A5 STATUS. REVEW PACKAGE l

nho STRUCTUllRL gp$$ y ppygyp. y;yy op (,pp,

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STEEL RET.DRD MUERWlED Ab STRTOS 1

3J. INTERNAL REVIEW REIMSPECTION Cl4ECKLICT.

CONNEC7 IONS:

Ef0PD DOCUMENTED AS STATUS. KEVIEW

)

60SSET PLATE PACKAGE ONGS. FOR RPPLICABillTY DF i

Ul55ETflATE.REDRb Rl4ERifED AS STATUS-1 3CINTERNhL REnEM MINSPECTIO!VCHECKLIST. MLORD CONNECTTONS-IZruAFNTED AS STATUS. REVIEW PK6. 0VtG5 l

WELDS FOR APPUCABillTY Of TNTERNAL CDMAECTIoE l

WHb5. }lECMD REVERITIEb A3 STATUS f

3 IRTEflML REMIEW KUM5PECTIlW CMCLll5T. RECDRD 9

CDNNECTEDIES: Doct:WNTED AS STATUS. KVIEW Pl%. DKS.

EDLTING FDIC APPLICMITY OF INTERNnt QWHICTI0tS 80Lil%.NConD RlWRITKD AS STATUS 3L BRACE REtaEW MINSPECTM CNEttLI,5T. RECORD CONNECTTON:

DOCUMINTED A5 STATUS. REVIEW PK6. DW65.

WELDS FDR APPLICBMIT1 DF MnCE CLNUECTINV whiD5. RECORD REVERiflED AS STATUS i

4c. BASE PLATE-EVIEW REWSPECTADN CMcKUST. RECORD DOClMENICD A5 STATUS.REWEW PK,l..DiULS

}

M APPUCMITY OF BASE PLATE.

RECORD REVER:F!fD AS STATUS l

i-l

1. WEREWAY /

REtlEW REINSWCTION CHGCKLIST l

CONDUTT RECORD DOCUMENTED AS STATUS.

j INSTALLATION l

CHECKLIST fREPARED BY MTE CHECKLIST APPROWO 8Y MTE INSPECTOR DATE LEAD INSPECTOR D9TE 1

s-

%,.o a

a. in

TO:

M. A. Clinton FROM:

L. A.

Shea

SUBJECT:

Verification of Training The use of the reverification checklist and the change in Attribute

7 of Category I Conduit Hangers checklist instructions Rev. 4 were discussed during a training session held with all of the Electrical Inspectors prior to starting the reverification inspections.

As the training session was not docuraented the following inspectors attest to their attendance of this training:

&L 1

KtHL t% 4AM M9%)

VA6xfL

/r 7W GLR. 5 /hl[/ L5(Ok-

i g

i a Page 1 of 4 REVERIFICATION RESULTS LEGEND / ATTRIBUTES EFFECTED BY CATEGORY Number of Attributes Legend Description Effected A

Attributes Inspected - Should be N/A 37 B

Attributes Recorded N/A and Documented on Non-10 Applicable Attribute on the Checklist -

Attribute Applicable and Reverified as Acceptable C

Attributes Recorded N/A - Inspection Required and 1

Reverified as Rejectable.

D Attributes Recorded as Acceptable - Reverified 5

as Rejectable E

Originally Rejected and Observation Written -

1 Additional Observation Written on Attribute No. 7 as a Result of Checklist Revision Total 5I i

l i

l l

i l

l l

(16763) t

Page 2 of 4 REVERIFICATION RESULTS (REFER TO PAGE 1 LEGEND-ITEMS IN PARENTHESIS)

CHECKLIST ATTRIBUTE OBSERVATION ATTRIBUTE CSR PACKAGE NO.

CORRECTED EFFECTED INITIATED /NO.

OBSERVATION

1. CSR-I-E-COH-01 YES (A) 39 & (D) 7 CSR-I-E-COH-01-03 7

2. CSR-I-E-COH-02 NO

3. CSR-I-E-COH-03 YES (B) 2f &

NO (B) 4c

4. CSh-I-E-COH-04 YES (A) 3D, (A) 3f CSR-I-E-COH-04-04 7

& (D) 7

5. CSR-I-E-COH-05 NO

6. CSR-I-E-COH-06 YES (A) 3f, (A) 3g NO

& (B) 4c

7. CSR-I-E-COH-07 NO

8. CSR-1-E-COH-08 YES (A) 2f, (A) 3f, NO (A) 3g & (B) 4c

9. CSR-1-E-COH-09 YES (A) 3g NO

10. CSR-I-E-COH-10 NO

11. CSR-1-E-COH-12 YES (B) 2f, (A) 3f NO and (A) 3g l

12. CSR-I-E-COH-13 NO

13. CSR-I-E-COH-14 NO

14. CSR-I-E-COH-15 YES (A) 3f, (D) 7 CSR-I-E-COH-15-03 7

15. CSR-I-E-COH-16 YES (A) 39, (B) 7 NO l

16. CSR-I-E-COH-17 YES (A) 3g

17. CSR-I-E-COH-19 YES (A) 3f, (A) 3g NO

18. CSR-I-E-COH-20 YES (B) 2f, (A) 3g, CSR-I-E-COH-20-01 7

(B) 4c, (D) 7 l

(1676J)

y Page 3 of 4

19. CSR-I-E-COH-21 NO

20. CSR-I-E-COH-22 NO

21. CSR-I-E-COH-23 NO

22. CSR-I-E-COH-24 YES (A) 3g NO

23. CSR-I-E-COH-25 NO

24. CSR-I-E-COH-27 YES (A) 3g

25. CSR-I-E-COH-28 YES (A) 3g NO

26. CSR-I-E-COH-29 YES (A) 3g NO

27. CSR-I-E-COH-30 YES (A) 39 NO

28. CSR-I-E-COH-31 NO

29. CSR-I-E-COH-32 YES (A) 3g NO

30. CSR-I-E-COH-33 YES (A) 3f, (A) 3g NO

31. CSR-I-E-COH-34 YES (A) 3d, (A) 3f NO

32. CSR-1-E-COH-35 YES (A) 7 NO

33. CSR-I-E-COH-37 NO

34. CSR-I-E-COH-39 YES' (A) 3g NO

35. CSR-I-E-COH-40 NO

36. CSR-I-E-COH-41 NO

37. CSR-1-E-COH-43 NO

38. CSR-I-E-COH-44 NO

39. CSR-I-E-COH-45 YES (A) 39 NO

40. CSR-I-E-COH-46 YES (A) 3g NO

41. CSR-I-E-COH-47 NO

42. CSR-I-E-COH-50 YES (A) 2f, (A) 3g NO

43. CSR-I-E-COH-51 NO (1676J)

o

(.

Page 4 of 4

44. CSR-I-E-COH-53 YES (A) 3g no

45. CSR-I-E-COH-54 NO g

46. CSR-I-E-COH-55 YES (B) 2f, (C) 3d, CSR-I-E-COH-55-08 (3d) 3d, (A) 3g, (D) 4c, CSR-I-t-COH-55-09 (4c) 4c, 7 (E) 7 CSR-I-E-COH-55-10 (7)

47. CSR-I-E-COH-56 NO

48. CSR-I-E-COH-57 YES (A) 3g no

49. CSR-I-E-COH-59 NO

50. CSR-I-E-COH-60 YES (A) 3g NO

51. CSR-I-E-COH-61 YES (A) 3g yo m

l (1676J)

-OW

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n REVERIFICATION OFCSR CONDUIT WGER REINS &ECTION

_v CSR PACKEE NUMBER:CSR-I-E-COH-o s.

SUFF0RT NUMBER: ds o-3326 A l

ATTRI8tRE SPECIAL INSTRUCTIONS INSRBfARTE RGER.By/04tr DOCUMENTED AS REVERIFIED AS ACTION TAKEN N 5 MEN i

REVIGN REIMSPELTIDW OKOGIST. RECORD RUI. STEEL

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GUSSETflATE.MDRb REVERifKD AS STATUS Sf. INTERNAL REnEM MINSPECTIMCHECKLIST. RECORD rnu LPH i

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REVIEW REINSWCTION CHECKLIST

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CONDUTT RECDRD DOCUMENTED AS STATUS-12 T Y 2_6 - E C REi' 0d5tavario+

j INSTALLATION cS N-E- catt-o r -03 l

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7. WEREWAY /

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7. WEREWAT /

RLtlEW REIN 5WCTION CHECKLIST CONDUTT RECORD DOCUMENTED AS STATUS. JLE '/3/95 N i lY,- A mc INSTALLATION , nduir A r / co D%TALLEO' CHECHLIS? PREPARED BY DATE CHECKLIST APPROVED BY IMTE INSPECTOR DATE LEAD INSPECTOR D4TE N LL dilef AT&lw

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7. WEREWAT /

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7. WEREWAT /

REilEW REINSWCTIDN CHECKLIST NRR lf0 ACLEPT&D REk'RE O CONDUTT RECDRD DOCUMENTED A5 STATUS. IN5TALLATION 1-/L-S5 2-7-85 AU f filp A 04 E I; j

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T 1 g , y, x EVALUATION OF THE BRAIDWOOD CONSTRUCTION ASSESSMENT PROGRAM by the INDEPENnENT EXPERT OVERVIEW GROUP i L' 'hPucM173 EXHl81T B6 e/c A Senatog hporting 12-232-0262

<c g 'p FIELD OPERATIONS ,.g EVALUATION 3 755 s.,,,,,on o.,i, g,gno,y CCSEATCH suite soo COWPOWATION Mington. virginia 222o2 (7o3) 979-822o December 13, 1985 BCAP-321 aoo o.= nio9. Turno.m. Suite So1 oak Aioge. Tennessee 3783o (615)482-7973 Mr. T. J. Maiman, Manager of Projects Commonwealth Edison Company 72 West Adams Street P. O. Box 767 Chicago, Illinois 60690

Dear Mr. Maiman:

It is our pleasure to submit to you this final report of the IEOG concerning its overview of your Braidwood Construction Assessment Program (BCAP). We have performed a thorough, searching assessment of BCAP and have faithfully reported our activities and findings to you on a continuing basis in our monthly and interim reports. This, our final report, indicates that we have completed our evaluation of the technical and programmatic aspects of BCAP and that we have monitored all areas of the implementation of the BCAP. A discussion of the methods and techniques we have utilized to conduct our assessment and our conclusions and recommendations are included in this report. We have enjoyed this opportunity to work with you on the Braidwood Construction Assessment Program. Your staff and contractors have afforded us every opportunity to conduct the assessment with the full disclosure of information which you expected. We are available to discuss our report with you if you should wish to do so. Sincerely, / Jchn L. Hansel C Perject Mcnr.;cr J LP. :VLC:fs Enclosures - 10 cc: E. E. Fitzpctri:k ?. J. O'Cenner R. E. Gcrdner W. Ehewski N. Kaushc1 M. We.11ece -5 J. G. Keppler IEOG Members W. Little File - 2 G. Marcus

, o l, - .y EVALUATION OF THE BRAIDWOOD CONSTRUCTION ASSESSMENT PROGRAM by the INDEPENDENT EXPERT OVERVIEW GROUP organized and supported by EVALUATION RESEARCH CORPORATION December, 1985 26 s ,f'f cha L. hans el /Lyne T. Cnss6 \\ l'f. cject Mansper and Scnier D:pcrt i'rincipal Consultant ) ^- \\}-Z'+s!Ci~ .~ / b.t.L.f L' }s.-V C yq[," '.iicnoics n. I e L:.T. h hc L c r t. V. Laney Senior Expert Senior Expert

e; . V TABLE OF CONTENTS Title Page 1.0 I NTRODUCT I ON........................................... 1 2.0

SUMMARY

OF CONCLUSIONS AND RECOMMENDATIONS............. 3 3.0 GENERAL ASSESSMENT OF THE BRAIDWOOD CONSTRUCTION ASSESSMENT PROGRAM (BCAP).............................. 4 3.1 Introduction...................................... 4 3.2 Credibility of the Internally-Managed Program..... 6 3.3 Technical Competence of BCAP Personnel............ 7 3.4 IEOG's Appraisal Methods......................... 10

4.0 ASSESSMENT

OF CONSTRUCTION SAMPLE REINSPECTION (CSR).. 13 4.1 CSR - Introduction................................ 13 4.2 CSR - Concept, Documents and Procedures........... 13 4.3 CSR - Plan Implementation........................ 14 4.4 CSR - Evaluation of Results....................... 17 4.5 CSR - Conclusions................................ 20

5.0 ASSESSMENT

OF REVERIFICATION OF PROCEDURES TO SPECIFICATION REQUIREMENTS (RPSR)..................... 21 5.1 RPSR - Introduction............................... 21 5.2 RPSR - Assessment of Implementation............... 21 5.3 RPSR - Evaluation o f Result s...................... 22 5.4 RPSR - Conclusions............................... 23

6.0 ASSESSMENT

OF REVIEW OF SIGNIFICANT CORRECTIVE ACTION PROGRAMS (RSCAP).......... 24 6.1 RSCAP - Introduction............................. 24 6.2 RSCAP - Assessment of Implementation.............. 24 6.3 RSCAP - Evaluation of Results..................... 25 6.4 RSCAP - Conclusions............................... 25

7.0 ASSESSMENT

OF BCAP QUALITY ASSURANCE (BCAP QA)........ 27

8.0 CONCLUSION

S AND RECOMMENDATIONS....................... 28 9.0 APPENDICES............................................. 29 A. IEOG Scope......................................... 30 Protocol Governing Communications................. 32 B. Brie f His torical Ba ckground of the IE0G........... 33 C. Qualifierri-m Friofe for the IFOG Project Mancerr and Triu:.N i Censulttu cnd the Senicr Erpertt.... 35 D. Statement of Independencc.......................... 38

4 . v

1.0 INTRODUCTION

In March 1984, Commonwealth Edison Company (CECO) contracted with Evaluation Research Corporation (ERC) to provide a team of experts with supporting staff to conduct an independent, searching evaluation of CECO's Braidwood Construction Assessment Program (BCAP). Commonwealth Edison's Chief Executive Officer, Mr. J. J. O'Connor, directed this Independent Expert Overview Group (IEOG) to examine BCAP's scope documents (including all policies and plans), program implementation, and any discrepancies found, and i to advise him whether the BCAP was carried on in a manner which would fulfill its stated objectives. (A brief outline of the IEOG Scope is presented in Appendix A.) Mr. O'Connor assured free access to all personnel and information which the IEOG determined would be required to carry out this assessment. The BCAP program of reinspection of completed work, review of construction procedures, and review of significant corrective action programs was undertaken by CECO to give additional assurance of the quality of Braidwood's construction in addition to that provided by the normal management and quality controls of CECO and its construction contractors. The BCAP program is described fully in five basic documents,

namely, Braidwood Construction Assessment Program, June 1984 (Rev. 2 issued December 1984); BCAP Overview Plan, Rev.

2, November 1984; Construction l Sample Reinspection Plan (CSR), Rev. 3, March 1985; Reverification of Procedures to Specification Requirements (RPSR), Rev. 1, August 1984; and Review of fignificant Corrective Action Programs (RSCAP), Rev. 3, January 1985. These policy documents are supplemeeed by a Project Procedures Menual. l T (1) 1 4 y _.--------.4 ,.r-.y. m-w,,-,,,y-n,mm,,-..,6,,,-,,,w y.,__-mr-..m---,y,r,wy-r-_.._y. r,._-._.---+_.----,---e----.,_~,,,y %,-,ew-

4 e This is the final report of the IEOG. It has been preceded by four Interim Reports. This report contains a section titled " General Assess' ment of BCAP," followed by sections on the assessment of each of the three principal elements, namely CSR, RPSR, RSCAP, and a section assessing the performance of BCAP QA. The IEOG's conclusions concerning each element are found in the section on that element. Conclusions concerning the entire BCAP program are found in section 8.0, Conclusions and Recommendations. A brief historical background of the IEOG is provided in Appendix 1 B; qualification briefs of the IEOG project manager and principal consultant and the senior experts are in Appendix C; and a statement of IEOG independence appears in Appendix D. 1 f I T d (2) i 9

.I .e 2.0

SUMMARY

OF CONCLUSIONS AND RECOMMENDATIONS As requested early in 1984 by Mr. J. J. O'Connor, the Independent Expert Overview Group (IEOG) has performed an independent, searching overview of the Braidwood Construction Assessment Program (BCAP). This is the final report of that overview. In overviewing the BCAP, the IEOG: (1) reviewed in depth the qualifications of the BCAP management and assigned personnel; (2) assessed the effectiveness of the design of the probram, its plans l and its procedures; (3) assessed the implementation of the program by surveillances,

reviews, discussions, over-inspections, and auditing; and (4) reached conclusions concerning the results of the program.

The conclusions and recommendations of the IEOG resulting from this overview are summarized below: CONCLUSIONS o The BCAP was soundly designed and documented to achieve its established goals. o The program was implemented in accordance with programmatic and procedural requirements. o The conclusions drawn in the final report of BCAP are supported by the results obtained from the program. RECOMMENDATIONS The IEOG recommends that CECO give vigorous management commitment to completing the unfinished corrective action programs reviewed by BCAP. The IEOG endorses the BCAP recommendation that CECO further ("r.luttc fi ec cttributo arec-cnd twe doce: cr.t e:1 n arecs even though these are belicved not to have design cignificance. In addition, the IEOG recommends expeditious actien by CECO to c1cc: the h3's that resulted frc. tb ECAP. l (3)

3.0 A CENERAL ASSESSMENT OF THE BRAIDWOOD CONSTRUCTION ASSESSMENT PROGRAM (BCAP) 3.1 Introduction As stated in the basic Braidwood Construction Assessment Program document of June 1984 (also known as the BCAP Policy Document), CECO undertook the BCAP program "as a prudent measure to answer any legitimate questions concerning the overall quality of construction of the Braidwood Station" (page ES-1). The BCAP is intended to add confidence in construction quality over and above that provided by CECO's normal management and quality controls governing construction. These inspections and reviews were included under the program designated as the Braidwood Construction Assessment Program (BCAP). As delineated in the BCAP policy document, the objectives of BCAP were to assure: o that there were no programmatic design significant problems in the construction of Braidwood which had not been identified and addressed; o that the on-site contractors' procedures governing the ongoing safety-related construction and quality assurance activities had addressed all applicable decign and regulatory requirements; and o that where past construction problems had been identified which resulted in significant corrective actions, such corrective actions were adequately implemented and documented. BCAP vas tr.de up of three principal elecer.ts : reinspection e cf completed safety-related construction work and c reviewing of related construction documents (CSR), e review cf (4)

safety-related construction procedures (RPSR), and a review of the implementation of nine ongoing corrective action programs which addressed previously identified construction deficiencies (RSCAP). The first two of these, CSR and RPSR, were complementary with respect to the periods of time which they addressed. CSR examined the adequacy of construction which had been completed and accepted as of June 30, 1984, and RPSR examined the adequacy of construction and inspection procedures extant as of June 30, 1984 which would be used to continue construction to completion. The IEOG attaches some importance to this complementary feature of CSR and RPSR because, taken together, they span the entire time period of Braidwood's construction. I It is expected that there is great similarity in the quality of construction performed before and after June 30, 1984. This similarity derives from similar program features, such f as common construction contractors, common CECO and contractor QA

programs, and common construction and inspection procedures.

With this perspective, it is reasonable to believe that construction quality after June 30, 1984 is equivalent to construction quality before June 30, 1984 except for specific improvements introduced by corrective action programs (addressed by RSCAP) and by incremental improvements in methods and procedures (addressed by RPSR). In this section, the IEOG reviews several aspects of the BCAP which a:e central to the credibility of the progrs= end to the 1EOG's evt.luction thercei. Tnese inclutt a critical examination of the safeguards required to establish the (5) i

e credibility of an internally-managed assessment and BCAP's implementation of each; an assessment of the professionalism and technical competence of BCAP project personnel; and a description of the IEOG's appraisal methods. Each of these is discussed separately. 3.2 Credibility of the Internally-Managed Program The IEOG believes that, under the safeguards discussed below, an internally-managed appraisal of construction quality can be effective and reliable. Although the advantages of performing an audit from within rather than from outside of the construction organization may be obvious (ready access to people and records, cooperative attitudes, full disclosure), the safeguards required to assure that the appraisal is objectively performed may not be as well understood. The IEOG was particularly interested to learn what measures had been taken to assure that BCAP was objectively designed and performed. To be fully credible, an internally-managed appraisal must be conducted under an unequivocal mandate from senior management. In this case, the IEOG observed firsthand the unmistakable commitment of CECO management to a thorough assessment. Management's instructions to BCAP were to perform a searching and forthright evaluation, and the IEOG was instructed to verify and advise CECO management whether these instructions were carried out. Adequate resources for both the BCAP Task Force and the IEOG were provided by CECO management. I r. cit' ' r t c h t v'r.t d ~r r tsnegement suppor*, c r, ecu-ful c prt.isci cust be pe r f ormc ( by pcreennel who have had no prior responsibility for the vo:k being cxamined. The BCAP g (6)

satisfied - this requirement by using technically qualified personnel from independent contractors not previously involved at Braidwood working under CECO direction. The prior work activities of these personnel were examined by BCAP management to assure that they had had no previous involvement. The IEOG also observed the openness and candor of CECO's periodic description of BCAP activities in public meetings. Ten meetings, held between September 1984 and October 1985, af forded members of the public an opportunity to follow BCAP progress, to hear the views of the IEOG on the conduct of the BCAP, and to raise questions of their own. In the opinion of the IEOG members, CECO's presentations at these meetings were clear and accurate, thus adding significantly to the overall credibility of the program. For all of the above reasons the IEOG believes that the BCAP benefited from the clear advantages of an internally-managed assessment while retaining full objectivity. l 3.3 Technical Competence of BCAP Personnel The IEOG examined the credentials of BCAP's key managers, believing that the strength of their qualifications in education, training and experience was an important indicator of their ability to carry out their assigned l responsibilities. In addition to reviewing key personnel resumes, IEOG members met at frequent intervals with each of the principal BCAP supervisors and with many of the j discipline engineers. We were impressed with their previous work crpericn:c, tirir unicrr:aniing e f I:!.? objectivec and their exec 11ent prefensional qualifications. By using such I competent and experienced professionals from other i (7) = -.

4 . e . organizations to assess the work of CECO and its contractors, BCAP added further to the evidence of program integrity. To demonstrate the technical strength of the BCAP team, the IEOG cites, as examples, the professional experience of the three persons who were directly responsible for carrying out the three principal BCAP elements, namely CSR, RPSR and RSCAP. Albert A. Patterson, CSR Supervisor, employed from an independent engineering contractor. Mr. Patterson is a Mechanical Engineer with over 24 years of experience on various types of power plant projects. He directed a confirmation program involving inspection of construction work and related documentation of a nuclear station; participated in an audit of quality of construction and adherence to design requirements at another nuclear station; was a Project Engineer for an Independent Design Review of design and construction for a third nuclear station; and was a Project Engineer on two other nuclear stations. Alfred P. Amoruso, RPSR Supervisor, employed from an independent engineering contractor. Mr. Amoruso has 30 years of progressively responsible experience in naval engineering, power project engineering and project management. He has broad experience in the maintenance and operation of fossil and nuclear power plants including planning, orp ririq, 5 :' r r I f. n;, tes:ing, t;prert, c,unlity s s surt.r.ce, spare pcrt p r oc urece r.t, and trciniq. At one nuclear power station he was assigned as (8)

Project Manager of the Independent Third Party Assessment of the Construction Completion Program. This work involved evaluations of construction, engineering and quality control activities. At another nuclear power station he held various responsible positions, including the position of Project Manager. His work on the Continuing Services Project involved consulting services for the engineering and design of backfit and maintenance tasks. While in the Navy, he carried out many responsible assignments. Among these were the command of a nuclear submarine repair tender; command of a nuclear submarine; and Deputy Chief of Staff for Logistics, Submarine Force, U. S. Pacific Fleet. Michael P. Dougherty, RSCAP Supervisor, employed from an independent engineering contractor. Mr. Dougherty has over 17 years experience in quality assurance and quality control associated with various nuclear facilities. His responsibilities have included the testing and inspection of manufacturing and cons truction activities. He was the Quality Assurance / Quality Control Supervisor for the work his company and its subcontractors performed at LaSalle County Nuclear Station. At the Zion Nuclear Power Station, he was a Quality Control Engineer responsible for field inspection in the civil-structural area, welder qualification and material documentation. As a Field Engineer, he perferact field intrectien of cracrete end reinforcing cteel. At the Donald C. Cook inscler.r Power Station, as a Field Piping Engineer, he was l (9)

responsible for vendor and documentatien inspection. This kind.of substantial professional experience, reinforced by personal contacts with numerous BCAP team members over many months, gave the IEOG considerable confidence that the BCAP team was directed by knowledgeable and respensible managers. The fact that these managers were from organizations which had no previous Braidwood responsibilities further increased the IEOG's confidence in the objectivity of their professional judgement when applied to decisions affecting the BCAP program. 3.4 IEOG's Appraisal Methods As noted in the preceding paragraphs, the IEOG gives considerable weight to CECO management's strong apd visible commitment to a sound BCAP program, to its frank public reporting of the program and to the high professional quality of the BCAP staff. These checks, although valuable, are not the only means by which the IEOG tested the validity of the program. The IEOG directly evaluated the BCAP program in two other ways. The first of these was to assess the effectiveness of the program design and content. This included evaluating its conceptual framework, the clarity of its procedures, the selection of appropriate populations and samples, the timely gathering and training of personnel, and the maintaining and utilizing of reliable records. By examining these and related factors, the IEOG assessed the program's design, logic and structure to determine whether it

would, if correctly pericreed, cccomplish its stetcc pu nesc.

(10)

The second method of direct evaluation was to observe BCAP's methods of implementing and conducting the program to determine whether it was executed in accordance with the governing policies and procedures. In the course of carrying out these direct assessments, the IEOG reviewed and made detailed comments on: o all revisions of the five basic program documents (previously identified in section 1.0) o all revisions of the procedures for carrying out the program; o all revisions of the attribute lists; o all revisions of the inspection checklists; o all revisions of the document packages o the reported observations; and o the evaluations of design significance. In addition, the IEOG and its staff performed surveillances of selected BCAP inspections, performed independent inspections of work samples of its own selection, and audited the adherence to BCAP procedures and the effectiveness of the BCAP QA overview of the program. The IEOG conducted five audits of BCAP, six audits of BCAP QA and participated as observers in eleven other audits of BCAP conducted by BCAP QA. Additionally, the IEOG conducted 320 overinspections of work camples which had been reinspected by -

BCAP, 105 reviews of supporting documentation and 21 surveillances of BCAP inspectors while they were performing their reinspections.

The IEOG reviewed corc than 2,70C ECAP observations and reviews conducted by Sargent and Lundy for design I (11)

significance, as well as a significant sample of Sargent and Lundy's calculations supporting their evaluations. Some of these observations were subsequently invalidated by BCAP for reasons which the IEOG evaluated and found to be acceptable. Through the activities of its people assigned on-site and the periodic visits of its people not assigned on-site, the IEOG maintained close observation of day-to-day activities and a steady dialogue with BCAP and Sargent and Lundy personnel. By the means described, the IEOG gained detailed familiarity with the soundness of the program, the thoroughness with which it was performed and, thus, acquired a capability for judging the validity of its results. As a result of its total activity, the IEOG issued 24 concerns to the utility. Each of these has been answered by a satisfactory response from BCAP and has been closed. l (12) _.m.--_ .._.v._

e 4.0 ASSESSMEfff OF CONSTRUCTION SAMPLE REINSPECTION (CSR) 4.1 CSR - Introduction The IEOG assessed the CSR as a distinct element of BCAP, while recognizing the interrelationships among the three program elements discussed in section 3.0. The following CSR assessment is presented in four parts:

concept, documents and procedures; plan implementation; evaluation of results; and conclusions.

4.2 CSR - Concept, Documents and Procedures The IEOG reviewed, discussed with BCAP management, offered comments on, and, in the end, gave its concurrence to the initial CSR Plan and all revisions thereof including the CSR Plan, Revision 3 dated March 1985. The IEOG, likewise, reviewed and concurred in the governing CSR procedures. By reviewing these documents during their development, discussing them with responsible BCAP personnel and concurring with them in final

form, the IEOG came to understand the rationale of the CSR plan, its concept and its internal structure and discipline.

We placed particular emphasis on how the populations were selected and how BCAP determined that the chosen populations adequately represented the entire safety-related work scope. The IEOG examined the step-by-step method prescribed for creating lists of completed and accepted work and the method for sample selection within the populations. We met with the consulting statistician who advised BCAP management and discusred sc ple ricer and sc ple selectien ec-thedr. es well as how inferences can justifiably be drtvt fro the inspection of saeples. The IEOG s itr il a rl y revieved the (13) t

methods used to select safety-related attributes, to create inspection checklists to guide the inspectors' work and to assemble installation documents and quality records. By such reviews and discussions extending over several months, the IEOG arrived at the conclusion that, in their final form, CSR program documents and procedures established a program which would, if effectively implemented, indicate whether completed safety-related work meets the design requirements and was free of previously unidentified programmatic, design-significant discrepancies. As used

herein, a

programmatic discrepancy is one causad by a p rocedural or programmatic deficiency and is, t;h e re f o re, prone to recur whenever the deficient procedure or program is utilized. In reaching the above conclusion, the IEOG notes that remedying discrepancies discovered by BCAP is not BCAP's responsibility but is assigned to PCD. The

BCAP, as structured, required that Non-Conformance Reports (NCR's) be written by PCD for each valid discrepancy.

The IEOG notes that PCD has issued the required NCR's for valid BCAP discrepancies, but the IEOG has made no assessment of their disposition. However, the IEOG urges CECO management action to clear these NCRs as soon as possible. 4.3 CSR - Plan Implementation As stated in the preceding section, the IEOG concluded that the CSR program was well designed and documented; that implementing procedures were adequate; and

that, if effectively irpiece::ed, the propre-vould fulfill its I

purpose. In tes L e c t ic.n, t.h t I W, d;u ribts the urns by which implementatior was asscssed and the conclusions r c nh6 J (14) j t

i Having previously found the program procedures to be satisfactory, the IEOG's assessment of the implementation was directed at observing that procedures were faithfully followed; that reinspections and document reviews were e f fectively performed by independent, qualified inspectors; that observations were accurately reported and validated; and l that analyses for design significance of these observations were based on reasonable assumptions and appropriate calculations. During the period of program implementation, numerous changes were made in procedures and practices to obtain additional clarity or efficacy. The IEOG reviewed and concurred in each of these changes. The basic concept of the program and the consistency of its internal structure were not significantly altered. The CSR program encompasses thirty construction categories of which two, Cadwelds and post-tensioning, were subjected to documentation review only. The remaining twenty-eight categories contained a total of 76,272 items in the populations. From these, a sample of 2,658 items were selected for reinspection. This sample was made up of a random sample (1,659 items), an engineering judgement sample (897 items) and items which were more highly stressed (102 items). These inspections resulted in 1,995 discrepancy l reports (valid observations) being written by BCAP l inspectors. The CSR document reviews involved some 2,736 samples covering the thirty populations. The number of documents and pieces of information checked numbered in the tens o f theus an:'s. (Ter furtStr dircunien en therc 1 1carc see the ECAP Report of tiovc=ber 1985.) ] (15)

I i It is evident that an extemely large number of reinspections and document reviews were required. To define the reinspection ef fort, to report observations and to evaluate design significance resulted in a very large number of documents. Taking this large number into account, the IEOG assessed the adequacy of program implementation by: reviewing a substantial sample of observations; o performing audits of the implementing process; o performing overinspections; o performing surveillances of BCAP inspections; o performing reviews of quality documents supporting o the hardware; o monitoring BCAP QA audits; o reviewing a sample of evaluations for design significance performed by S & L; and o assessing the BCAP staff's performance in validating and evaluating the significance of observations. During its review of documents and its performance of audits and overinspections mentioned above, the IEOG carried on a continuing dialogue with the BCAP staff to obtain clarifications

and, in some instances, to suggest modifications in program activities.

By these means, the IEOG obtained clear and current knowledge of the performance of individual BCAP staff members and their conformance with the spirit and letter of governing plan., and procedures. The IEOG's questions and suggestions were met with a consistent professional attitude. It became clear that Ceco management's intent to conduct a

thorough, objective reint;ection propre-vts undcrtto:d cnd impleror.tcd et all levels of the Ceco cnd Scrgent and Lundy organicctions.

l (16)

Although a number of program procedures were adjusted to reflect early learning experience and although there was a sid-program suspension of inspections for two days to allow time for retraining inspectors, the IEOG observed a general and consistent attitude of faithful compliance with program objectives and procedures. As a result of its direct observations, dialogues,

audits, and overinspections conducted over approximately nineteen

months, the IEOG concludes that the CSR program was implemented in faithful compliance with its basic purpose and in conformance with its detailed procedures, 4.4 CSR - Evaluation of Resulta a

Each of the 2,658 sample items was reinspected for appropriate attributes which had been defined on written checklists. Each attribute usually involved a number of inspection points. As a

result, the total number of inspection points was

large, namely 653,130.

The CSR hardware reinspection resulted in 1,995 discrepancy reports I containing 10,358 insignificant discrepancies, 2,166 notable discrepancies (about 0.3% of the inspection points) and no { discrepancies which affected the item's ability to perform l its safety-related function. Notable discrepancies are those which have a 10% or greater effect on capacity but no effect on ability to perform safety-related design function. 1 Although no design significant discrepancies were identified, BCAP recommended further follow-up action by PCD on five specific attributes : mortar fill for masonry wall columns; running bend ct =cconry vs.11 intersections; conduit attachment ta hanp rt; c:.iifer.cri for electrical equipnent; j and missing HVAC hcnger welds. e 1 l (17)

i t, I The CSR documentation review revealed that adequate construction documentation exists. Although there were numerous minor discrepancies in document entries, these were not found to be significant in terms of the quality of plant hardware. As a result of this document

review, BCAP recommended that PCD further evaluate three discrepant documentation areas, namely: grouting for base plates and patches, electrical welder qualifications and HVAC welder qualifications.

The IEOG attaches considerable importance to the fact that the responsible architect / engineer, Sargent and Lundy (SEL), evaluated the hardware discrepancies and found none to be design significant in terms of plant operability or safety. SLL found that the excess margins provided in the design were such that the required design margins and code requirements were not impacted by any of the hardware discrepancies and that each item's ability to perform its intended safety function was unaffected. The IEOG has examined two particular questions related to the CSR reinspection results noted above. These are: 1. What is the significance of finding 2,166 " notable" discrepancies in this reinspection? What does it imply about the original inspections? 2. Is it reasonable that none of the 2,166 " notable" discrepancies should be found to be design significant? Dces finding 2,1 H ditcrepancies on a reinspectic:. of co::picted and accepted vork cast doubt on the e f fec tivenes s ci thc c : ip i n 4.1 tr. re:: irns? The !L% centidered three f4.ctert in reaching cn answcr to this questien. I (18)

First: The reinspectors were very much aware that their reinspections would receive unusually close scrutiny, including overinspections. As a result, they were motivated to inspect stringently. Second: Many inspection attributes are subjective, and thus enabic a reinspector to exercise increased stringency. Third: The reinspections were performed against the latest approved drawings and specifications. These were, in some cases, more demanding than those to which the original inspections had been performed. Taking these factors into account, the IEOG believes that the observed incident rate of notable discrepancies of 0.3% is not excessive and does not reficct unfavorably on the effectiveness of the original inspections. With respect to design significance, the IEOG reviewed numerous CSR observations concerning discrepant hardware conditions together with Sargent and Lundy's evaluations of their design significance. These evaluations were discussed with responsible SLL engineers who performed the evaluations and with the BCAP engineers who also reviewed them. In all cases the accumulation of favorabic excess margins which occurred in the normal design process was sufficient to make the discrepancies inconsequential in terms of plant safety and operability. The IEOS notes a: ro that all discrepenties are recorded on non-cc..i :rcr.a

i,..:t G r a ? h.r ; roject atte.u.en.

ICAP further recommended that the project give particular attenti>n to five hardwcre quality attribute and three I (19)

discrepant documentation areas which, although not design significant, occurred with enough frequency to merit follow-up. In summary, the IEOG made its own direct assessment of the CSR discrepancies, Sargent and Lundy's analyses of them and BCAP's assessment of these analyses. From these investigations, the IEOG was convinced that the discrepancies found do not affect the ability of the hardware to perform its safety-related functions or reduce margins below the level required by code and conservative design practice. Hence, none was design significant. 4.5 CSR - Conclusions Based on its overview of the CSR program as described above, the IEOG believes that: o The CSR program was well designed to fulfill its stated purposes. o The CSR program was faithfully implemented in accordance with established program plans and procedures, o The conclusions of CSR in the BCAP report are valid. 5 I (20)

5.0 ASSESSMEfft OF REVERIFICATION OF PROCEDURES TO SPECIFICATION REQUIREMENTS (RPSR) 5.1 RPSR - Introduction The purpose of RPSR was to assure that, as of June 30, 1984, on-site contractors' construction and inspectior procedures governing ongoing safety-related construction and quality assurance activities address all applicable design and regulatory requirements (BCAP Program Document, page I-2). 5.2 RPSR - Assessment of Implementation Almost all of the IEOG's appraisal methods as described above in section 3.3 of this report were used in evaluating the effectiveness with which the BCAP team prepared and carried out the RPSR Plan. These included reviewing of, commenting on, and concurring with the initial issue of and all revisions of the basic RPSR program plan and procedures; evaluation of lead personnel and their performance through frequent personal contacts; and observing their understanding of and adherence to the RPSR plan and procedures. The IEOG reviewed the selection of safety-related requirements for use in evaluating the procedures. These requirements were obtained from the FSAR and from the specifications written by Sargent and Lundy. The IEOG also reviewed the choice of contractor's construction and inspection procedures for comparisons. The IEOG reviewed the RPSR checklists which record requirements from the SLL specifications, the FSAR, codes and standards referenced in the TS/.R and in the SLL construction specificat hrt.; tnd :he cir.rs uicet!:n of t'.cra :ogairc:ents as safety-related or non-safety-related. The IEOG n1no reviewed the observation

wrftten whi ~ ver thc pr :cdures (21)

failed to meet the criteria in the checklists. Finally, the IEOG reviewed the process whereby the resulting observations were evaluated for validity. This process resulted in identifying three valid concerns involving three contractors. 5.3 RPSR - Evaluation of Results The first of the three valid concerns notes the absence from the procedures of a requirement to control the welding sequence and the distortion of structural members during welding. BCAP's analysis of this omission concluded that it had no effect on installation quality because the contractor used qualified welding procedures and verified the welds by QC inspections. Additionally, the Pittsburgh Testing Laboratory also inspected the welds visually. A second concern recorded a failure of the contractor's inspection procedures to specify a requirement for penetration depth of construction expansion anchors installed in concrete which had a repaired surface. BCAP's analysis concluded that, since the missing requirement was included in the construction procedures of the installation contractor, no effect on past construction was expected. Nevertheless, CECO committed under an NCR to a reinspection of any anchors in repaired concrete. The third concern recorded a missing requirement in the procedures that liquid penetrant testing of structural welds cover a minimum of one-half inch of thu adjacent bare cotal cn ( at : sih sf the weid. L C AP ' t. cr.alysb ns th t.: thir omission had no effect on past construction since the cent racre-reg,'!rer ths.t cd'accnt areas I c l c r.nc ? f or one (22)

inch on either side of the weld and, in practice, penetrant material inspects more area than is required because of the manner in which the penetrant is applied. 5.4 RPSR - Conclusions Based on the overview of the RPSR program as discussed above, the IEOG reached the following conclusions: o The RPSR program was effectively designed and documented to achieve its established goals. o The RPSR program was implemented in accordance with established program policies and procedures. The results achieved by the RPSR program provide a o sound procedural basis for proceeding with construction. l I (23) t

6.0 ASSESSMEfft OF REVIEW OF SIGNIFICAlff CORRECTIVE ACTION PROGRAMS (RSCAP) 6.1 RSCAP - Introduction The objective of RSCAP was to assure that "where past construction problems have been identified which resulted in significant corrective actions...the corrective actions have been adequately implemented and documented." (BCAP Program Document, page 1-2) RSCAP is to " consist of a cocumented assessment of each of the eleven (11) separate programs identified below. (RSCAP Plan, Rev. 3, page 3) 1. Reinspection of Safety-Related Mechanical Equipment 2. Quality Control Inspector Reinspection 3. Piping llent Number Traceability 4. Quality Control Structural Steel Review 5. Electrical Installation Documentation Review 6. Safety-Related Pipe Supports 7. IIVAC Welding 8. HVAC Configuration 9. IIVAC Duct Stiffener and Fitting Detail 10. Instrumentation Installation Verification 11. NSSS Component Support Verification" It should be noted that the three llVAC significant corrective action programs were later combined into one, thus leading to nine (9) programs. 6.2 PSCAP - Anger.sment of Irpicinentatior. RSCAP was intended to assure that these programn ruitably n t.'. u n t 4 / nii i t'e n '. ! f ' e d dircrepane9r. r.re em ' * ::e r.t s (24)

lW l l arising out of the previous construction problems and that each contractor's procedures addressed ala commitments. RSCAP required implementation reviews utilizing checklists to determine if each contractor conducted the program in accordance with the procedures. As in CSR and RPSR, the IEOG reviewed the initial issues of and all revisions of RSCAP

policies, procedures and checklists, and reviewed the resulting observations.

The IEOG discussed RSCAP progress with responsible BCAP managers l and engineers at regular meetings. From these it was noted that, as a result of BCAP's intensive initial reviews, several of the corrective action programs were upgraded. Following this upgrading, BCAP performed later reviews which were the basis for their final conclusions. 6.3 RSCAP - Evaluation of Results The IEOG found the RSCAP reviews to be thorough and effective. As a result of these reviews, several of the programs were upgraded. RSCAP's later evaluation found procedures and ' implementation to be proceeding ef fectively. The RSCAP program has successfully validated the individual program procedures and the completed and ongoing implementation. The program has developed and documented a credible basin for concluding that those programs which are still incomplete will be effectively completed. 6.4 RSCAP - Conclusions Based on its overview of RSCAP activities, the IEOG concluded th:4 t : o The prograe vs.c suitally dcsigned and docuttented to achieve its established objectives. (25)

o The program was implemented in conformance with established program policies and procedures. o The implementation of the RSCAP was thorough and resulted in strengthening several of the corrective action programs. o The program achieved its established purpose. I (26)

-.i 7.0 ASSESSMElff OF BCAP QUALITY ASSURANCE (BCAP QA) In line with the IEOG scope, the IEOG performed a program to audit each part of the BCAP operation. After the IE00 had completed its first round of BCAP procedure audits, its emphasis was shifted to the auditing of BCAP QA and to observing the BCAP QA audits of i I BCAP. IEOG observers participated in eleven BCAP QA audits. This allowed the IEOG to assess the quality and thoroughness of audits performed by BCAP QA while still ensuring proper adherence by BCAP to its established procedures. The IE00 retained the prerogative to conduct spot audits but, since BCAP QA continued to execute its audit program in an acceptable manner, the IEOG did not find it necessary to resume the auditing of BCAP. The IEOG continued its active program of auditing BCAP QA. Of the eleven audits the IEOG conducted, six were audits of BCAP QA to determine if BCAP QA was in compliance with its own procedures. This program of observing BCAP QA audits and auditing BCAP QA by IEOG auditors provided a basis for the IEOG to assess the implementation of the BCAP program as well as the BCAP QA program. Since quality of construction was the goal towards which the program was directed, it was important to conduct all parts of the program with concern for quality assurance methods. BCAP QA ensured that BCAP performed its various functions in accordance with previously approved quality assurance policies and procedures and in accordance with approved BCAP procedures. Compliance with there provided a beris for cerfidenet in the conclurions rcrehed by thc LCAP. I (27)

8.0 CONCLUSION

S AND RECOMMENDATIONS The IEOG has evaluated the programmatic and technical aspects of the BCAP and has monitored its implementation. From its independent overview, the IEOG concludes that: o The BCAP program was soundly designed and documented to achieve its established goals. o The implementation of BCAP was in accordance with established BCAP policies and procedures. o The conclusions drawn in BCAP's final report are supported by program results. The IEOG recommends that Ceco give vigorous management attention to completind the unfinished corrective action programs reviewed l by BCAP. The IEOG endorses the BCAP recommendation that CECO further evaluate five attribute areas and two documentation areas l even though these are believed not to have design significance. l l Additionally, the IEOG recommends expeditious action by CECO to l clear the NCR's that resulted from the BCAP. l l l (28)

O I i l l 9.0 APPENDICES (29)

Appendix A l IEOG SCOPE As delineated in the BCAP policy document published in June 1984, the IEOG scope included the following: "--Conducting an overall review of the BCAP scope document objectives and a review of each of the BCAP elements to determine if the BCAP elements will fulfill their objectives." "--Ascertaining if the BCAP effort, as identified in the scope documents, is properly focused and whether the goals of the BCAP are being fulfilled." "--Conducting audits that will address the implementation of l each of the BCAP elements. Items to be specifically I audited will be adherence to Program procedures, evaluation of quality assurance involvement, qualifications of the personnc1 performing inspections, and identifications of non-conformance and adequacy of the i i corrective actions." l "--Pe r fo rming an independent review of selected { BCAP-identified discrepancies to provide assurance that l the engineering evaluation for design significance was adequately performed and documented." It wr.r. Mr. J. J. O'Connor's e x p re. n o intent that the IEOC be c or:p l e t <. h f : u to c or.d u e: an aart.stment cf the prot rac. by any means deemed necost.ary. Toward this goni, the IEOG scope was furtl e r de fined in a le r t s r of /.rpp

36, I C S c. f r e J. Connor I

(30)

to J. G. Keppler regarding the conduct of BCAP to include the following: "... perform field inspections, audits and surveillances of installed equipment, hardware and in-process l inspections..." "... issue monthly reports..." "... review some observations to assure that appropriate ones are being documented as discrepancies (NCR's)..." "... review a sampling of implementing procedures of the Quality Assurance Overview Group..." "... review a sampling of disci eoancies for which design calculations were performed by the A/E to support their evaluation for design significance..." i Attached to this letter was a protocol establishing communication l channels between Ceco, ERC and the NRC. A copy of the current l protocol is attached to this Appendix. (31)

PROTOCOL GOVERNING COMMUNICATIONS BETWEEN COMMONWEALTH EDISON ~C6HPANY AND EVALUATION RESEARCH CORPORATION (ERC) IN THE ERAIDWOOD CONSTRUCTION ASSESSMENT PROGRAM 1. This protocol communications between Commonwealth g(overns Edison Company CECO) and Evaluation Research Corporation (ERC) in its capacities as the Independent Expert Overview Group).in the Braidwood Construction Assessment Program (BCAP 2. All exchanges of correspondence, including drafts, between ERC and CECO will be submitted to the Administrator of NRC Region III at the same time as they are submitted to CECO. 3. ERC has a clear need for prompt access to information and activities required to fulfill its role. To this end, ERC may request documents, meet with and interview individuals, conduct telephone conversations, conduct audits and inspections, establish and witness program hold

points, review work and inspection activities, and undertake similar activities without prior notification to the NRC staff.

4. As a normal program function, ERC may meet with CECO' daily, or as necessary, to discuss program activities such as licensee work

schedule, licensee activities overviewed, action items identified, action taken on identified items, resolution and close-out of these actions, audits conducted, and hold points witnessed.

These meetings shall be open to NRC staff attendance. A record of the conduct of such meetings will be kept by ERC. These records will be available on-site for review by the NRC. [ 5. CECO and ERC shall meet with the NRC staff, initially conthly, to discuss previous periods activities. Topics to be addressed will include the status of action items and any problems encountered. The meetings shall be open to public observation and shall normally take place on the first Thursday of each month at 9:00am and shall normally be held at a location in the vicinity of the Braidwood Station. l Minutes of the monthly meetings shall be prepared by CECO and transmitted to the NRC and ERC. 6. All ?neurer:t t r' r ' t e ' to or tre.s-! u d bv the R C rubjcet '.i: .ces. ~ 'm ,.w-0.t

U.s ;

the M. '" f t:.ic Document nocen ir. Wilmingt n, Illincts n-d Kashington, D.C., cad will be a v a i l t.b l e there for public e x a r. in a t ion at;d e g yir;.. Revicien '. . i,.a. > (32)

's. Appendix B BRIEF HISTORICAL BACKGROUND OF THE IEOG To provide an independent overview of all the activities of BOAP and to provide an independent assessment of the efficacy of BCAP, Mr. J. J. O'Connor, CEO of CECO, established an Independent Expert Overview Group (IEOG). As an outside organization to bring together such a team of experts to form the IEOG, the Evaluation Research Corporation (ERC) of Arlington, Virginia was retained by CECO. ERC assembled a team of senior experts and essential staff under the direction of Mr. John L. Hansel. 1 Initially, the program was entitled the Quality Requirements j Verification Program (QRVP) and consisted of those corrective action programs later included in the Review of Significant Corrective Action Programs (RSCAP), one of the three elements of BCAP. Outlined below are some of the significant program milestones: 1. March 19, 1984: ERC received written authorization to begin work in support of CECO on the QRVP. 2. March 26-27, 1984: The senior experts, which became the IEOG, first met in the Chicago offices of CECO. 3. March 23-April 27, 1984: CECO redefined the program and released the first draft of the BCAP plan on April 27, 19E4 (33)

U.. -4. June 1984: CECO released the first official version of the BCAP. This policy document was then followed by a BCAP Overview Plan, three separate element plans for Construction Sample Reinspection (CSR), Reverification j of Procedures to Specification Requirements (RPSR) and Review of Significant Corrective Action Programs (RSCAP). 5. July 22, 1984: CECO forwarded the BCAP plan to the United States Nuclear Regulatory Commission (NRC) for l its review and acceptance. 6. July 27, 1984: Mr.

Keppler, NRC Region III Administrator, responded to CECO with a set of comments and recommendations and a suggestion for a protocol to govern interactions between ERC, CECO and the NRC.

7. August 30, 19S4: Mr. O'Connor of Ceco responded to Mr. Keppler's comments and recommendations establishing, among other things, the protocol to be followed for communications between the IEOG, CECO cnd the NRC. 8. September 6, 19S4: The first BCAP status meeting was held between CECO, ERC and the NRC. This meeting was open to the public as authorized by the protocol. Additional meetings were held subsequent to this on October 4, 1984; November 8, 1984; December 6, 1984; January 3, 1985; rebruary 14, 1985; March 14, 1985; April 11, 1985; and June 25, 1985. The tenth and final r_.. ing vc.r it'.J C :dcr '.;, '. 9 ! !.. (34)

,1 - o e Appendix C QUALIFICATION BRIEFS FOR THE IEOG PROJECT MANAGER AND PRINCIPAL CONSULTANT AND THE SENIOR EXPERTS Nr. John L. Hansel's professional career encompasses more than 30 years of experience in the management of large complex programs for major energy and aerospace projects. His management and technical experience covers a wide range of projects, such as the Apollo and Space Shuttle programs, the Mark VI Re-entry Vehicle Program at Cape Canaveral, the Department of Energy's Gas Centrifuge Enrichment Plant Project, and the Three Mile Island investigation where he participated in a Special Study Team. Mr. Hansel recently served on an independent review panel commissioned to study and mr.he recommendations for improvements to the Nuclect Regulatory Commission quality assurance controls that are levied on utilities for the construction of nuclear power plants. In cddition to the Three Mile Island investigation, he has provided quality assurcnce end reliability consulting se.rvices to three utility companies involving four nuclear power plants. He hcs published numerous papers cnd articles on reliability, safety and quality control, and is currently serving as President of the American Society for Quality Control. Additionally, he received the National Aeronautics and Space Administration's Astronaut Recognition Award for sustained superior performance in support of the Apollo and Space Shuttle programs. Mr. W enc L.

Chese, D.

F Scr "cre than 25 ycere cf broad e:.g inet ring nnd r.. . c. n t r. t c.perience in the nuclear in du r t r;. cnd is a consulttnt in nue:ce.r er.ergy. ".e Fne extensive experience in prcje - c. n l e r i. < < u. ; c .1 i

e..

c.1 I (35)

3. phases of engineering

design, development, procurement, construction, and checkout and operation of

reactors, fuel processing plants and test rigs.

His experience also includes writing safety analyses reports and defending designs and design philosophies before the NRC and ACRS. He has participated in contractor selections and contract negotiation, and managed the design of the heat transport systems for CRBRP, FFTF and Fermi. Mr. Robert V. Laney is an experienced consultant in nuclear energy and energy project management. He has broad executive and technical expertise in power plant operations, energy research and development, the construction and operation of large energy projects, and the cc=ple::it ies of bringing new nuclear stations-into use. His experience includes participation in design and construction of the first nuclear submarines, surface ships and utility-operated nuclear pouer stations. He developed the first ec=prehcasive 'cuality assurance program for the Navy's nuclear program. As General Dynamics Vice President and General Manager of the Quincy, Massachusettes Shipyard, he was responsible for the 4 design and construction of a number of nuclear powered ships and submarines. He later became Deputy Director of the Argonne National Laboratory responsibic for the development of advanced energy technologies. He currently provides consulting services to a number of utilities in nuc1 car station design assessment, construction quality assesstent and station operation. He is a member of the Board of Directors of GPU Nuclear Corporation and holds - degrees from the U. S. Naval Acadecy, the Massachusettes Institute of Technclogy and the University of Chicago. t (36) ~

...y , o Mr. Nicholas A. Petrick, P. E. has been Executive Director of the Standardized !!uclear Unit Power Plant Systems (Si?UPPS) project since it was established in 1973. The project includes the recently completed Callaway and Wolf Creek nuclear units. In this position, he has had responsibility to the SNUPPS Utilities for .managen.e n t of the work done by the A/E (Bechtcl) and for. coordination of

design, licensing, quality assurance, and procurement.

He was with the Westinghouse Bettis Laboratory for 17 years, from the establishment of that facility. At Bettis he was directly involved in the design of the first submarine prototype reactor core and had management responsibility for reactor and plant design on a number of naval and commercial power plants. In 6 years at the Westinghouse Advanced Reactors Division he was Engineering Manager of the Fast Flux Test Facility and Project Manager of the Breeder Deconstration Project (later Clinch River). He has a brocd background in detailed design, project management and construction of naral, e::perimental and co=cercial - nuclear plant systems. (37)

..c ) O Appendix D STATD:ENT OF INDEPENDENCE As the Project Manager for this overview activity, I certify that the IEOS has maintained independence from other organizations at the Brt.idwood Station and that the IE00 has received cor plete cocperation from the prcject pcrticipants. rs f / / / \\ ci-l./,,,, Q '.s ~ - _ ;. / ohn L. I:cnsel Prcject :cr.cgcr i t i (36)

..h o g E_AP OBSERVATION RECORD Page 1 of 3

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w..: e v.,c Dy L. K. COMSTOCK ENGINEERING COMPANY, INC. Memorandum Tom Sommerfield Tm Office: Braidwood Tom Corcoran p Signafure n Quality Related Documents Date: November 15. 19E

Subject:

Generated by LKCE QC Braidwood Site " " "~" FOR INF0WEl:N ONI_Y Per your request the following mutually agreed upon clarification regarding our joint meeting of week of 11/12/82 for what is meant by a signature on a quality document is as follows: l. A Level I Inspector's signature signifies what he observed in performing an' inspection. 2. A Level II Inspector'sisignature on a Level I inspected document signifies that he is certified in the area for which the Level I signed for. This is to consist of his review of the Level I Inspector's ICR/NCR/ Inspection checklist, etc is; a) complete b) legible c) trackable d) clearly defines the status of - the item inspected. NOTE: He may elet.t to re-inspect any aspect particularily to; a) completeness of the report b) verify condition reported by the Level I's findings c) clarify the Level I report d) satisfy himself that the Level I was adequately trained to perform the inspection reported for. 2.1 A Level II reviewer's signature for a Level II certified inspector who performed the initial inspection in the specific area covered does not have to be certified for the specific topic he is re-3 viewing documents for. The initial Level II Inspector, however, must be certified for the area the reports affect. 2.2 The reviewer's Level II primary role in reviewing a certified Level II originator's documents is responsible for; a) completeness b) trackability of all relative documents / references, revisions of drawings, etc. c) clearly defines the status of the item inspected for. NOTE: A Level II reviewer cannot re-inspect a Level I or another Level II's unless specifically certified for the type of

m' e . L..,. c e, c. s.C r. \\ t inspected area affected such as; a) cable pull b) weld inspection c) configuration .f.) e ra NOTE: If re-inspection is warranted or deemed advisable, the reviewer is to obtain another Level II. who is certified for the specific procedure to be employed in concert with his review. 3. Quality Manager or his designee's signature does not require he be certified for# nspection" but shall signify he is qualified to analyze i all pertinent records for: . a) Certified Level II Inspector's performing in specific ..i. areas are utilized for the quality reports. b) Trained Level I's Inspectors perform itial in-spections are properl trap j cific area being r I b r 1 ative to P/N # engineering / procedure instructions. t t ocuments are complete. That all reports define correctly the requirements and e specific nonconformance in sufficient detail to permit ICR/NCR review dispositions, actions as a consequence of reporting nonconformances. NOTE: The use of a" referee action"by Quality Management or his designee is permitted only at a Supervisor / Engineer or higher t.echnical level, subj ect to the customer's (CECO) concurrence. The rationale and disposition on reporting inspection findings must be clearly stated.on QC records subj ect to audit review or confirmation as to acceptability. 4 Quality Management or his designee's signature shall be indicative of proper and accurate statenents as to Corrective Action Taken and To Prevent.Re-occurrence, subj ect to audit (findings) by the originating auditor for acceptability. D N Tom Corcoran QC Manager TFC/tja cci Doug Brown Frank Rolan Rick Saklak Mike Kast C. K. S tiles W. A. Gardner . f'lle

(u u September 5, 1985 / BCAP Memo #3269 To: N.N. Kaushal From: G.M. Orlov/L. Shea/D.J. Patel subject: Invalidation of Observations - _. ~ The observations #CSR-I-E-EIN-112-02, CSR-R-E-CND-110-01 and CSR-R-E-CND-XXX-84 were determined to be invalid by the CSR engineers for the. reasons states in Part 3 of the observation forms. The Level II inspectors who wrote these observations had declined acknowledgment of the invalidation of these observations. Therefore, as required by BCAP-06, Section 4.4.5, a comunittee consisting of Mr. G.M. Orlov, Mr. L. Shea and Mr. D.J. Patel discussed disposition of these observations and recommend that you or your designee sign these observations as invalid. Mr. L. Shea, the Level III electrical inspector concurs that the reasons stated in Part 3 of these observations are sufficient to justify invalidation of the observations. Mr. L. Shea has agreed to sign these observations on-behalf of you upon receiving your approval. ~ . O, b d G.M. Orlov gg QA Assistant BCAP Director %{yW N *g[gdud 0/ k c_ D L. S ea Level III Electrical Inspector f D.J. Patel CSR - Lead Electrical Engineer cc: BCAP File 69.20.19 QG 69.30.1 QG 69.60.3 QG 69.81.5 (200lJ) l (

p s

BCAP OBSERVATION REmmi Page 1 of 3

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/ Braidwood 4.8.1 L. K. COMSTOCK & COMPANY. INC. l CLASS lE SAFETY RELATED CONDUlT INSPECTION REPORT y,3_ pp CONDUlTID C//9dD) [ CONDUlT SIZE " J - 8" SEG CODE ,.7 0 5.- f < LOCATION FROM /tygIcJd/// TO /Jdo# A ELEV._ ft7' DCR/FCR/ECN //// INSTALLED BY /, Edgg cf / ~ DRAWING NO. JOS- / ~1.Jc) f REV. 7 ACC R EJ N/A 3.1.1---CONDUlT -lNSTALLED PER. DRAWING _.. l l R 3.1.2 SEPARATION MAINTAINED hI l R 3.1.3 CONDUlT PROPERLY SUPPORTED l l 3.1.4 FIELD CUT / EXPOSED THREAD COATED PER S & L FORM 1895F l l U 3.1.5 CORRECT COUPLINGS /8USHINGS INSTALLED Cl l 3.1.6 BEND RADIUS MAINTAINED l l NONDUlTS PROPERLY ID'D 3.1.7 UU 3.1.8 SHARP EDGES REMOVED UU 3.1.9 GROUNDING COMPLETED l l l l REMARKS i EIRA A'"inki nasi 11 IW tl Ul%IVIN < IUll URL T M' shrh.2 Thw Ynva%A.-

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I e BCAP OBSERVATION RECORD Page 2 of 3

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' f.. J V-1 )f V. INDEPENDENT EXPERT OVERVIEW GROUP f Commonwealth Edison Company has retained the services of Evaluation Research Corporation (ERC), of Arlington, Virginia as an outside organization that will bring together and direct a team of experts whose purpose will be to provide an independent overview of the f, BCAP. ERC has formed this team of senior experts and professional staff to work under the direction of a Principal Consultant. ERC team members are well qualified to perform the independent expert overview function. Summaries of key ERC team member qualifications can be found in Appendix C. The Independent Expert Overview Group activities include the following: Conducting an overall review of the BCAP scope document objectives and a review of each of the BCAP elements to determine if the BCAP elements will fulfill their objectives. Ascertaining if the BCAP effort as identified in the scope documents, is properly focused and whether the goals of the BCAP are being fulfilled. Conducting a minimum of two (2) audits that will address the implementation of each of the BCAP elements. Items to be specifically audited will be adherence to Program procedures, evaluation of Quality Assurance involvement, qualifications of the personnel performing inspections, and identification of nonconformances t and adequacy of the corrective actions. Performing an independent review of selected BCAP identified discrepancies to provide assurance that the engineering evaluation for design significance was adequately performed and documented. Preparing in-depth audit reports. The results of the overview will be submitted in periodic reports to the Manager of Projects with a copy to the President and Chairman of the Board of Commonwealth Edison. These heucMr'5 seestnew l57 "/5 A Exmsli s nfn4m

9 V-2 %[ g-reports will not be discussed, in any manner, with non-authorized members of Commonwealth I Edison Company management or personnel or with any management member or personnel of Commonwealth Edison Company associated contractors. ERC personnel conducting the BCAP overview will be organized in task teams, consisting of f a senior expert team leader and professional staff. The task team will operate independently of the various Braidwood organizations and will communicate with Commonwealth Edison through a designated Commonwealth Edison representative. The task team will have access to Braidwood Station and access to contractor personnel, facilities and records associated with the Braidwood Station. l-In the event that the Independent Expert Overview Group discovers any discrepancies with potential significance relative to the BCAP implementation or observations with the potential for program changes, such discrepancies or observations will be properly f documented and submitted to the designated Commonwealth Edison representative. All such discrepancies will be resolved to the satisfaction of the Independent Expe t Overview Group. An in-depth final report will be submitted to the Manager of Projects with a copy to the President and Chairman of the Board of Commonwealth Edison Company. This report will include all task team findings, observations and associated dispositions, along with overview group recommendations. The Independent Expert Overview Group members will be free of any significant contacts with Commonwealth Edison Company. They will not have participated in the design, construction or quality assurance activities related to the Braidwood Station or with Braidwood site contractors within the past five years. Immediate family members will not be currently employed by Commonwealth Edison Company or a Braidwood site contractor. Members of their immediate family (parents, spouse, children and grandchildren) will not currently have a cumulative ownership and creditor interest in Commonwealth Edison Company or a Braidwood site contractor which exceeds 5% of the family annoal income. W L-t

o V-3 )f f' in short, the independent Expert Overview Group will conduct a comprehensive third-party overview of the BCAP, thereby providing an added measure of assurance in the reliability of the results of the BCAP. f f I I 'e W 4 e I I l. 1}}

ML20214D870

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Enclosure:

SUBJECT:

SUBJECT:

SUBJECT:

Dear Mr. Maiman:

SUMMARY

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5.0 ASSESSMENT

6.0 ASSESSMENT

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8.0 CONCLUSION

1.0 INTRODUCTION

SUMMARY

8.0 CONCLUSION

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ML20214D870

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Enclosure:

SUBJECT:

SUBJECT:

SUBJECT:

Dear Mr. Maiman:

SUMMARY

4.0 ASSESSMENT

5.0 ASSESSMENT

6.0 ASSESSMENT

7.0 ASSESSMENT

8.0 CONCLUSION

1.0 INTRODUCTION

SUMMARY

8.0 CONCLUSION

Subject:

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