ML20091E752
| ML20091E752 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 05/22/1984 |
| From: | Karr J STONE & WEBSTER, INC. |
| To: | Burgess B, Harrison J, James Keppler NRC |
| References | |
| SWM-123, NUDOCS 8406010354 | |
| Download: ML20091E752 (5) | |
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YOUR ATTENTION IS DIRECTED TO THE FOLLOWING:
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The following Closed CIO Item / Hold Point Notification (s) is (are) attached for your action /infomation:
.T1TM 0 69 DISTRIBUTION:
E. Karr Job File C.3 (orig + 1)
CIO Program ilanager DLQuamme, CPCo NIReichel, CPCo-RAWells, CPCo 840601o354 84o522
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Sheet I of 1 STONE & WEBSTER
"*U5fMBERl HOLD POINT NUM CONSTRUCTION IMPLEMENTATION
, O TRACKED ACTION ITEM OVERVIEW
@ TRACxEo iNFoRuAriON iTEu MIDLAND NUCLEAR PLANT./.0. N0.14509 O TRACnEo RECOuuENDATION ITEu REFERENCE (S)
O UNTRACKEDITEM CIO Evaluation No. MP-MIS-072-0001 O HOLD POINT NOTIFICATION CONDITION DETAILS 10CFR50, Appendix B, Criterion No. XVI corrective action requires, in part, that conditions adverse to quality be promptly identified and corrected. The January
-l 1984 Status Report (MPQAD Site Audits) indicated that 37 audit reports were open, of which 22 had been open for six months or longer, some dating back to 1981.
15 of the 37 audit reports had findings overdue.
Records revealed a failure to maintain audit report and related corrective actions (memo L.J._Barbieri to R.A. Wells 2/7/84).
A review of audits (open and closed) prior to June 1983 should be conducted to assure adequacy of auditing, proper close out of findings, compliance to 10CFR50, Appendix B, and objective evidence as to adequacy of past audits.
Please advise CIO of actions to be taken.
YES ' " "., ',
X no uo ATTACHMENTS INITpTO /
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fg(4, INITIATION APPROVED /DATE DATE RESPONSE REQ'D.
March 19, 1984
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RESPONSE
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See Attached The attached response (Attachment 1), along with CPCo Internal Correspondence RCSember to BHPeck, dated 5/10/84. Serial No. 29575 (Attachment 2) is acceptable and this Item is considered closed.
(PAGE
/3 No YES w o.'s t ATTACHMENTS EST. CORRECTIVE ACTION RESPONDENT TITLE DATE COMPLETION DATE RCSember J/fg/ P-(/
Audit Branch Head 3/13/84
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E RESPONSE VERIFIED / CLOSED DATE
//
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Iterii 059 I
,'RhspansatoCIOIten#059 Page 1 Of 2 The:first' paragraph re' ports there may exist a condition adverss to quality due to overdue and lack of attention to tracking Audit Findings.
The following is a summary and status of open Audit Reports which was developed
'from a status. report which the Audit Branch issues monthly to Consumers Power Company and Bechtel management.
I Status of Action Items 1.
Audit Reports with open Action Items = 33 2.
Audit Reports from #1 above, open 6 months or longer = 21
- 3.
Of #2 above, 11 Audit Reports are indefinitely extended.
4.
Of #1 above, open 6 months or less = 12 ' Audit Reports 5.
Of #2 above, only 7 of the cumulative 33 Audit Findings issued with 21 reports are beyond commitment date and all 7 have had remi;nders issued.
6.
Of #5 above, the remaining 26 Findings are not beyond the required commitment response date.
7.
From #3 above, the 11 Audit Reports involve a total of 45 Findings which were indefinitely extended as a result of no construction activities on Q work since 2/12/82.
8.
Therefore, the Status Summary indicates there are 21 Audit Reports (#2 above) open with action items 6 months or longer and of those 21,11 have been indefinitely extended because of no construction activity. Therefore, there are 10 Audit Reports open 6 months or longer. Of those 10 Audit Reports, there is a total of 33 open AFR/URIs.
Seven of the 33 are open beyond commitment date, with action item reminders issued and the remaining 25 are within commitment dates. Therefore, a review is not warranted at this time because all open action items are being tracked an'd are not judged to be creating conditions adverse to quality.
The second paragraph states that Audit Reports and related corrective actions were not being maintained.
In fact, the Audit Reports and related action items (AFRs, URIs) were being maintained according to MPQAD Procedure F-12M, Rev 4.
The requirement as stated in Rev 4 was for the auditor to maintain the original Report and Findings until closure of all outstanding action items and at that time, the Audit Report became.a Quality Record and was to be controlled as a Quality Record.
It should be understood that this was the practice prior to a singular dedicated audit activity being established on the Midland-Project and audits were previously conducted by individual disciplines. The-Site Audit Branch, with management agreement, made a. decision to centralize and control (and proceduralize -
this control) all past and related corr'ective actions. The memo from LJBarbieri to RAWells documented this activity and did not indicate in any way some previous failure to maintain Audit Reports.
It should be noted that all Audit Reports with-their respective action items have been accounted for at evidenced by Audit Log entries.
4 9
7 Item 059'
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,.. Raspons3 to CIO Item #059 Page 2 of 2.
-Page 2:
.. j 9
Paragraph three recommends a review of all audits (opened and closed) prior to June, 1983, to, assure-adequacy of auditing proper:close-out of Findings, compliance to 10CFR50, Appendix B and objective evidence'as to adequacy of past audits. There is no indication that the audits themselves, close-out of findings orLcompliance to 10CFR50 Appendix B are suspect. To confirm the adequacy of audits performed prior to June, 1983,.a nonstatistical sample will be reviewed and'an evaluation made over the next 12 months. This will also_ include a review of any. third _ party concerns.
Corrective action will be taken if required. The Site Audit Branch is. scheduling future audits which will provide a new look at the same activities and current status will be determined.
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To
~ BHPeck,' Midland Energy Center gc
- df FaoM RCSember, Audit Branch Consumers DATc May 10, 1984 Power Sussc er MIDLAND ENERGY CENTER PROJECT -
RESPONSE TO CIO ITEli 059 FILE 24.2 SERIAL 29575 col",Noorocc tc The purpose of this memo is to provide additional information/ clarification of the actions being taken by the Site Audit Branch regarding CIO Tracked Information Item 059. In conjunction with actions which took place as a result of our developing a tracking mechanism / matrix (Tracked Item 060 Item 2b) a review of past audit findings was performed.
Past Findings / Unresolved Items were also screened for appropriateness, correctness, and proper close out.
No adverse trends were noted and it was decided that there did not seem to be any major deficiencies in past audits.
During the normal course of preparing for new audits a review is made of past audits in the same area. Since most of the areas are audited, as a minimum, yearly, it is anticipated that during the next 12 months all past Audit Reports and Findings /
Unresolved Items should be reviewed in depth and any areas found deficient in past audits will be reaudited.
If you have any questions regarding our actions, please feel free to contact Mr L J Barbieri or me.
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