ML20091H765

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Forwards Complete Response to Nonconformance Identification Rept 22 Re Document Control & Update of Work Station Logs as Requested in Tracked Action Item 086
ML20091H765
Person / Time
Site: Midland
Issue date: 05/29/1984
From:
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
STONE & WEBSTER, INC.
References
CSC-7810, NUDOCS 8406050283
Download: ML20091H765 (9)
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Text

{{#Wiki_filter:? , . 50-3.29 3O G 

      -                                          CONSUMERS POWER COMPANY         50-33C MIDLAND ENERGY CENTER Transmittal No:                        CSC- 7810 Date: May 29, 1984 To:    Stone & Webster P O Box 1963                                                          -

1 Midland, MI 48640 PRI A A 

                                                                                                                  /       3 Attached Is:

Partial Response To w 4~/E 1C w - 1-- 5 Complete Response To _ For Your Information Ny 

                                                                         '      l     -[i~1e      ikkQ Other

Description:

Tracked Action Item 086. l l l l Signature: .

l. cc rJGKeppls r ,Pi NRC i- Rigibn L III Ew/ak, JJHarrison, NRC Region III w/a RJCook, NRC Site w/a .

RAWells, MPQAD w/a BHPeck, FEC w/a NIReichel, MEC w/a DDJohnson, }EC w/a f l LWorley, MPQAD w/a Dehorn, MEC w/a h j 31p i ( 8406050283 840529 $1 PDR ADOCK 05000329 I S PDR --

ITEM / HOLD POINT NOTIFICATION FORM Sheet 1 Of j ITEM NUMBER HOLD POINT NUMBER fTONE & WEJSTEX 086 CONSTRUCTION IMPLEMENTATION g TRACKED ACTION ITEM OVERVIEW O TRACKED INFORMATION ITEM N/Pl4NP ##ctE4X MANT./.0. NO.14509 0 TRACKED RECOMMENDATION ITEM REFERENCE (S) O uNTRACxED iTEu QAR RA-00155/QAR RA-00157 0 HOLD POINT NOTIFICATION CONDITION DETAILS Due to the conflicting responses received from Bechtel and that of MPQAD (See Reference below) concerning NIR 022/NIR 023, we request one reply clarifying our initial findings. Current replies provide inaccurate and conflicting information.

Reference:

1. Stone & Webster NIR No. 022 2. Stone & Webster NIR Nc. 023 CPCo Letter #CSM-0768 CPCo Letter #CSM-0769 OAR RA-00157 QAR RA-00155 (P AGE O Yes os) 0 NO ATTACHMENTS DATE RESPONSE REO'D. INITIATOR /DATE INITIATION APPR VE /DATE 24-84 Q Q & n0Q w s[tQ4g V)

F-22 -87 RESPONSE (SEE NOTE) attachments 1 and A provide a complete response to NIR-022. Attachments 2 and B provide a complete response to NIR-023. l (PAGE b YES NO'S) 7 NO g ATTACHMENTS 1, A , 2 & B EST. CORRECTIVE ACTION RES N. TITLE DATE COMPLET N D ATE hif hy RESPONSE ACCEPTED DATE RESPONSE VERIFIED / CLOSED DATE nott - POn inAcKEo ActlOn ITEwS OnLv. ExPLAlm cLE Anty on nEFEnEnct AttacHwfurg Pom:

1) CAUSE OP 08BEnVED CONDITION El CONNECTIVE ACTION TAKEN 3) PREVENTIVE ACTION TAKEN n ew a %

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       .                                                                            Attachment 1 Page 1 of 2 She following response is to clarify the response to your initial findings in NIR No. 22 as requested.in Tracked Action Item 086.

Note: For ease of reading, the findings have been numbered per attachment A and have been grouped by subject. Workprint station 219 is located with team 19. Distrik tion was done by Document Control and maintenance of the station was the responsibility of the team receiving the documents at the time of the audit. This workprint station has been transferred to a controlled satellite station.(main library) and placed under the responsibility of document control for maintenance as well as distribution. All workprints audited were new workprints (either distributed after the stop work order or reviewed in the conversion / verification process). This program is in line with our corrective action plan submitted in response to MCARR-DAT-1.

1. Missing pocuments (findings 1 and 11)

Documents were found to be missing at the workprint station. These have been corrected.

2. In-Process Work Activities (findings 2, 9,17)

In all cases, distribution (distribution may include new documents or gullbacks) had been made from document control and the distribution date (distribution date of pullbacks are not given on the register but were obtained from a pullback call up from the computer) was noted on the register. In some cases, the attachments in question were pu11 backs which had not been received by the station. Therefore, even though.the-register indicated an update, the station logs and documents had not been updated. 'Ihe changes had not been posted by the personnel at the j ~ workprint station. Therefore, the amendment stamp on the front of the drawing and the logs were not updated accordingly. No unreasonable time delays were found. A procedure to clarify posting requirements l (FPD-1.000) was issued on March 23, 1984. These findings would all be I in compliance with the new procedural requirements of FPD-1.000 which l requires posting be completed within three working days of the distri-l - bution date. Construction assistants were reminded that changes must be

completed in three working days per new procedural requirements (FPD-1.000).

l Discrepancies listed have been corrected. 3 .' Update of Work Station logs and/or Amendment Stamps on front of drawing to reflect conversion / revision (findings 3, 4, 5, 6, 7, 8, 9, 10, 14, 16, 18) Workprint station logs and/or amendment stamps on front of drawings were not updated to reflect workprints that had been converted / verified. Per-sonnel were reminded of' the need to update logs. Workprint maintenance requirements were reviewed with team personnel responsible for maintaining l workprints. ! This workprint station has been transferred to a controlled satellite

document station (main library). Workprint station logs / cards have been l standardized. Discrepancies listed have been corrected.

l i i l .

  • Attachment 1.

Page 2 of 2

4. Conversion / Verification Errors (finding 12, 13)

Change paper had not been removed, therefore, the workprint station log 

                   - and amendment stamp on the front of these drawings had not been revised.

The change paper has been removed from these drawings and the amendment stamp on the front of the drawings and the workprint station log have been corrected.

5. Legibility (findings 19, 20)

Drawings were replaced. Workprint personnel were reminded of the need to check drawing legibility.

6. Miscellaneous (findings 3, 10, 15)

Finding ,3 - FRL-1 was incorporated in drawing M-652-1-H130 Revision 1 and is presently not listed on the front of the drawirq as indicated cn the Audit Report. Finding 10 - Drawing M-18-176 is revision 1 per the register and the sepia. Finding 15 - Drawing M-18-370; there are 1064 pages including alpha and numeric pages. This total pga count is used for microfilming. j e 4

Attachment A ,, DIS.CEFPRNCIE~5 @ STf7T/ON 2 / 9 I^! U? 60CUMEWT REV REV DOCUMEN1~5 IN D51ED ON RTTCil. 7D OTHER , %* NUMBER D%E REG. IN GUESTION REG FRONT BRCH COMMENTS LOG-A A FCR H/0265 YES Il=.s AIo Yd5 

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 @ S452-I-H6                                      0          0    low 20 23              No        Yrs                Yes                                                                   Yes l    FRL/                   No        Yes               A/o                                                                  '>f=3
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& M-f 52-2                                          .3lrt 3lrt     /C S 8      A/n        b /Yo           hAln                                                                 YES '

& M- 652 H22 2 2 Iocn 20040 No No Ao . Yes & MIB-I5/ 5 5 rce 2191 s'zzn NHo YES AIo Yss 0 M18- 151 5 3 rea nW /22?l- No YES /Yo YES bM &S2-1 lllF/ //ff/ TCS ARIL /+' fGS YC5 YGS JVo G H 4 5 "2.-"I-Il/6 O' 'O rc R 3&z. Ne No Ato Yes 

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W/E/D52/'iTA"li 0 N652- /- H2 O. O INN 20119 Y NO No Yes  : 

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Attachment 2 Page 1 of 2 Se 'following response is to clarify the response to your initial findings 7 t

- :in NIR No. 23 as requested in Tracked Action Item 086.
             . Note:. For ease of reading, the findings have been numbered per attachment B and have been grouped by subject.

Workprint-station 209 is. located with team 9. Distribution was done by Docu-I' Control and maintenance of the station was the responsibility of the team

receiving the documents at the time of the audit.- This workprint station has been transferred to a satellite controlled document station (main library)
and placed under the responsibility of Document Control for maintenance as I well as distribution. Wis program is in line with our corrective action plan

! submitted in response to MCARR-DAT-1. Workprints that had not completed the conversion / verification process.or been distributed as new workprints since ' l the lifting of the stop work orders had not been released by MPQAD for Q-work. l 1. Old Workprints versus New Workprints "Old" workprints were eliminated by April 14, 1984 in the field. Se Document Control Assurance Group has not found any "old" workprints since April 14, 1984 and will continue to monitor. Senew workgrint process and copies of the workgrint stamp are described in FPD-3.000.

2. Discrepancies between Registers and Information on Sticks (findings 5, 6, 7,-8, 9, 10, 11, 13, 15, 16)

In all drawings identified in these findings, the register reflects the - new revision status which has been processed. However, none of these

_ drawings (or change paper) had been distributed. Se sticks should reflect previously distributed information. % is " historical" information is available in' System 38 and can be provided to the auditors upon request.

r p mis. processing cycle information was reviewed in the audit entrance i - 

                     ' meeting.                                                       !

nv'= ant Control has verified that all drawings and change paper that were noted on the audit report are correct on the sticks according to current i distribution status. No further action is deemed necessary.

3. Misinterpretation of Register Revision Information and Miscellaneous Discrepancies (findings 21, 22, 23, 24) , __

i %e auditors reviewed the home office revision information as opposed to the field status'which is the revision constructed to. (These are large ' 

                    = bore isometrics which are revised in the field to add additional welding information. (See procedure FPP-1.000). Therefore the wrong information was reviewed in the register.

Document Control reviewed the drawings against the field status, noted - 

                    . discrepancies and took corrective action as follows:

1 Finding -(22) - K R was removed 

                                            - ICS stamp wa2 placed on front of drawing Finding (23) - Status stamp was placed on front of drawing
                           . Finding (24) - ICS stamp was placed on front of drawing
                                                                                       .*------i,--..-..--.~.

      .                                                                                                       Attachment 2                         '

Page 2 of 2

4. Legibility (findings 2, 3, 5, 6, 7, 8, 9, 11, 12, 13, 14, 19, 23, 25, 26)
                       'Ihe Document Control Assurance Group reviewed these drawings at station 209 on May 23, 1984. It-was found that four.(4) of these drawings have been deleted from distribution for station 209. Nine (9) of these drawings have been superseded by later revisions and one u)'of these drawings was voided.
                     ~In all cases, the review for legibility of the existing drawings found the drawings =daglate for use by construction.
5. Change Paper not removed or added to Drawings (findings 4, 12, 17, 19)

Change paper had not been removed from or added to the drawings per pull 

                     'back instruction. Discrepancies have been corrected.
6. Other Miscellaneous (findings 18, 20)

An K N was not listed on the front but was attached. 'Ihis is a clerical error and has been corrected. Document Control is unable to verify the information in the audit report on finding 20. Additional information will be required.

7. Other Concerns noted on the Audit Report a) Training
                      'Ihe construction assistant responsible for this workprint location attended                                                    ,

training sessions on January 6, 1984 and January 10, 1984. Instructions on posting and other requirements of FPD-1.000 and FPD-3.000 were discussed. 

   .                  Document Control has also reviewed the requirements with the construction assistant since these training sessions.
        - -                                                                                                    I b) Processes followed in Workprint Stations
                      'Ihese issues will be resolved when the workprint stations are maintained by Document Control as part of the Document Control Corrective Action Plan.

Until this conversion is complete, Document Control will review training needs with the construction assistants and arrange for training as appro-priate. . _ L - I m 0-e 

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