ML20214E699

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Intervenor Exhibit I-ROREM-13,consisting of Requesting Submittal of Proposed Procedures/Revs for Document Review Process by 850220.Implementation Plan Also Requested by 850226
ML20214E699
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 05/07/1986
From: Shamblin D
COMMONWEALTH EDISON CO.
To: Rolan F
COMSTOCK ENGINEERING, INC.
References
1412A, BR-PCD-85-119, OL-I-ROREM-013, OL-I-ROREM-13, NUDOCS 8705220209
Download: ML20214E699 (2)


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Commonwealth Edison Co.

Braicwood Station R R 1. Som 81 Braceville, IL 60407 Telechone 815/458 2801

'87 fB 22 P6 Z9 February 6, 1985 BR/PCD 85-119 EEI.

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NUCLEAR REGULATORY COMVl5S!C5.

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1.. K. Comstock s Company Inc.

Braidwood Nuclear Power Station Bracev111e, Illinois 60407 tw it:n:o r-Au,;Sunt ECPC

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AtteMk F. Ro M fanft omt Project Manager Continctor CATE N~ b 60 #d Other W!tne:s subject:

Braidwood station - Units 1 & 2 S

i IJtC Document Review for Rhetfeds-Turnover /d N i

l Eeference: LLC Braidwood Procedures 4.13.1 and 4.13.2

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Dear Mr. Rolan:

Although the three phase document review established to satisfy past QA and NRC concerns is about complete, it appears the review may not have been i

l thorough enough to adequately address all of the document problems and corrective action commaitments. Recent observations documented by BCAP have supported this conclusion. In addition, it is commonwealth adison's intention that the document review performed at system Completion / Release (i.e. Release to operations) be one of administrat ive accountability. Prior to System Completion / Release the quality and credibility of the records saast be firmly i

established by L. K. Comstock. Consequently, Commonwealth Edison Ccapany considers it a prudent step to place the current Document Review Program on administrative hold and subsequently perform the document review originally planned per Procedure 4.13.2. Paragraph 3.4.1 ggw_ to preclude any last minute impacts on scheduled activities.

In order to achieve this goal LJtc is directed to develop a doctment review program, preferably in a Procedure 4.13 format with clarified scope and intent, to assure that each record in the IJtC QC file is identifiable, complete, and comprehensive. The review should encompass the criteria for acceptable documentation as specified in Procedure 4.13.1.

The review must be done by personnel trained in the specific requirements of the procedures governing the particular document being reviewed, and this training must be documented to assure objective evidence of compliance. A review checklist should be developed for each type of record delineating the generic checks, similiar to those in Procedure 4.13.1, as well as detailed instructions addressing the specific checks unique to the record being reviewed. sech doctment reviewed must reflect that the review was completed. the date reviewed, and the reviewer. In addition each document with deficiencies mast C0033514 0705220209 060507 373 PDR ADOCK 05000436 G

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l have an attachment (i.e. specific checklist developed for review) delineating the deficiencies *yt a clear concise description of the corrective action taken to clear the deficiency. The corrections must be made by an ANSI Level i

II or III Inspector certified in the applicable discipline the document encompasses. The deficiency record must be signed off by the certified inspector and gc Document control supervisor as objective evidence of compliance.

The review process must be established to review the records presently in the gc vault, and a system established to assure that the review is performed on new documentation received. To avoid any misunderstandings it is important that everybody involved understands that the object of this review is to assure that each record is identifiable (i.e. traceable to the specific item or process it encompasses), that each record is complete (i.e. includee all the information required to address each attribute specified on the record),

and thet each record is camprehensive (i.e. undesetandable so that antyone can readily deteruine the scope of the document and 1[he atatus of the activities affecting quality). In addition tJtc will revise Brahd Procedure 4.12.2 to identify the review at system completion / Release as primarily an accountability review rather than the review presently identified.

LJtc should submit to Cummonwealth Edison Project construction Departmoot proposed procedure / procedure revisions for review and comment hr plebruary 20th, IMS, and an implementation plan etlich includes proposed personnel allocations and schedule by February 26, 1945. Additionally, the unekly 1Jtc Quality control Department status Report should report progress against the agreed schedule.

If you have any questions or need assistance with this project contact Bud Schryer, (Ext. 2620).

1 l

very truly yours,

.._l D'.' L. shamblin Proj. Construction superintendent Braidwood Station l

MhS/kje (1412a) l cc: E J. Wallace i

T. E.,Quaka l

M. W. Eaushal O. E. Groth l

C. A. leennecke/J. W. Gieseker I

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v. s..vahl.

I. Deue14 - IJtC i

E. Seltaan - IJEC Coc0&M5

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