audit report no. bwip-ia-87-004, site characterization plan, … · 2012-11-19 · audit report no....

|*-Irnal

From: BWIP Quality Assurance DepartmentPhone: 6-8358 1135 Jadwin/18/1100 AreaDate: July 8, 1987Subjects AUDIT REPORT NO. BWIP-IA-87-004, '

PRODUCTION

; '12100-87-DDD-177

SITE CHARACTERIZATION PLAN,

� /,9// �lk /

TO. DE Mahagin

cc: DD DorseyDC GibbsJ GrahamGW JacksonJR Kirkendall

CDC-2/3000CDC-2/3000CDC-2/3000CDC-1/3000CDC-2/3000

KM Tominey FMIT Tr/300RJ Viens CDC-2/3000Audit FIle BWIP-IA-87-004RTJ:DDD File/LB

C., iiNCW-5007 Ub8 (iA

'The attached report presents the results of the RockwellHanford Operations Basalt Waste Isolation Project (BWIP)audit of the Site Characterization Plan, Production conductedMay 26, 1987 through June 17, 1987.

The scope, purpose, executive summary, and personnelcontacted during the audit are detailed in the attached AuditReport.. The Audit Report also includes the Audit Finding.Reports, Audit Observation Reports, and Attendance Sheets for,the Pre-Audit and Post-Audit Conferences.

Please provide corrective action responses on the originalAudit Finding Response Reports and Audit Observation Reportspresented at the Post-Audit conference. Responses must besubmitted to the BWIP Quality Assurance (QA) Audit GroupManager by the agreed to date.

K>~ Should you have any questions, please.Auditor, Westinghouse Hanford Company376-1987.

contactBWIP QA

DD Dorsey, LeadAudit Group on

RT Johnson, Manag;4't=Basalt Waste Isolation ProjectQuality Assurance Department

tak

Attachment

pDgRZPDR 1

Hanfora Operations anc Ergineerrg Contractor for ine US Deoanrmene of Energy

Page I of 5,, . -

,,SxI_

I,4Rockwell Hanfo OperationsBasalt Waste Isolatior Project AUDIT REPORT

. .

ACtIVITY AUDITEDREPORT NO. BWIP-IA-87-004

Rockwell/BWIP Licensing Department345 Hills St./3000 Area DATE OF AUDIT 5/26/87 6/17/87

PROJECT SWIP

AUDIT TEAM IName and Tife)

D. D. Dorsey, Lead Auditor R. 0. Mahood, Auditor-in-Training

H. Litz, Auditor/DOE-RL

SUMIL; RY

SCOPE:

I To verify implementation of responsibilities and requirements relative to controlSite Characterization Plan (SCP) production as set forth in Licensing DepartmentProcedures (PMPM's) 1-108, 10-102, 10-103, 8-111, and 8-112.

of

PURPOSE:-

The purpose of the audit was to evaluate the implementation of procedures (PMPM's) 'as they apply to the production of the SCP. Both Licensing and its interfaces withpersonnel from various other departments were examined.

EXECUTIVE SUMMARY:

This report presents the results of the'Rockwell Hanford Operations (Rockwell):Basalt Waste Isolation Project (BWIP) audit of the SCP production conductedMay 29, 1987 through June 17, 1987.

Thirteen findings and two observations were recorded. These reports documentprocedural noncompliance and/or poor business practices. Responses must besubmitted to the BWIP Quality Assurance (QA) Audit Group Manager by the agreed date.

The implementation of the above referenced procedural' requirements was determined tobe ineffective. Those areas which are significantly impaired by improper proceduralcontrol are:

1. The capture and retention of records which would provide the historical basisfor the validity of the rigorous review process by which the end product (SCP)was formulated (Ref. Findings 1, 3, 4, 6, 7, 9, 10, 12, and Observation A).

2. Training (Ref. Findings 2 and 11).

3. Interfaces between Licensing Department personnel and persons outside thedepartment; (Ref. Findings 5, 8, 13 and Observation B).

i __ _- , B- 8 7

.'f

R.'J. Viens, Manager BWIP QA Audit AoIT.om R Date_ _ _ _ _ _ _ _ _ _ r o wI n - .... . .. - -I

See �cvese ,.oe lot cOmoIe.,o.� ,flhttuCtOn,, A47OO23SIN� S3),

'S¢e feve-se woce for corDnow-o-% *smsirut.onsi A47700 235 IN T i3l ,

_ to* / 9P

AUDIT REPORTNO. BWIP-IA-87-004PAGE 2 OF 5

No evaluation of the technical content of the SCP was made and'no inference shouldbe drawn between the lack of procedural compliance and the technical quality of theSCP.

The following is a summary of the findings and observations:

Finding No. I

The SCP Review Comment Record (RCR) described in Revision O to procedure PMPM 10-102has never been used. The SCP RCR, or similar, shown in Revision 1, effective

*<_.- June 5, 1987 has been used exclusively as far back as July of 1986. Entries on- these forms are in many cases illegible, hand written, in pencil, in various shades

of ink other than the allowable black, and the forms used have been reproduced onpink, blue, green, and goldenrod paper and in various combinations of all of theabove. All of these are in violation of procedures and/or good business practices.

FindinQ No. 2 -

PMPM 13-106, Revision 1 requires that a determination of an individuals knowledge,;skills and abilities be measured against "established requirements" in order to beconsidered qualified. While a BWIP Review Qualification form has been filled out onall members of the Senior Technical Review Team (STRT) and about 25% of the LeadAuthors, no.requirements have been established with which to measure a personsknowledge, 'skills, and abilities.

Finding No. 3

'There is no evidence that the Licensing Department has established a system ofchecks and balances which will 'maintain and control" the SCP Guidance Manual in amanner which assures that users have, and are using, the latest revision.

Finding No. 4

The record hard copy of the Administrative Record is not being maintained as an yInProcess Quality Assurance Record" (Ref. PMPM 8-115, Revision 2) as required in PMPM10-103 Revision 0.'

Finding No. 5

SCP RCR's and copyright permission forms are being transmitted to the U. S.Department of Energy - Head Quarters (DOE-HQ) and the U. S. Department of Energy -Richland Operations Office (DOE-RL) by The Licensing Department personnel inviolation of the requirements of RHO-GM-MA-2, 14-06.1 which requires all outgoingcorrespondence to be signed by the Project Director. The sole exception granted to


this policy is correspondence to major project participants which is signed by aContracting Officers Technical Representative (COTR) to whom DOE has grantedapproval authority.

Finding No. 6

The Text Control Coordinator (TCC) is required to review allagainst a checklist called the SCP Text Acceptance Criteria.been devised to document this required review.

'_ Finding No. 7-

drafts of the SCPNo mechanisms have

The TCC is required to send a copy of each controlled draft, as they are returnedfrom Technical Publications, to the Lead Author for a final accuracy check prior tosubmitting the draft to the reviewers. Due to time constraints, the TCC is sendingthe drafts to the reviewers at the same time as the copy is sent to the Lead Author..

Finding No.8

PMPM 8-111, Revision 0 makes reference to an organization called "Data Management*and directs the Licensing Department personnel to forward documents to thisorganization. There is no such organization in BWIP as "Data Management.'

Finding No. "9

PMPM 10-103, Revision 0 directs the SCP Files Coordinator to complete a "CTPTransmittal"'per PMPM 8-113, Revision 1 to transmit documents to BRMC for'microfilming. This procedure and CTP's are only to be used to transmit raw data andnot documents.

Finding No. 10

PMPM 1-108 Revision 1 discusses "small group review" and resolving comments receivedfrom these reviews. PMPM 10-102, Revision 1 requires that all comments be recordedon RCR's, or other appropriate means, that documents concurrence with commentdispositions. While it could be argued that a marked up draft is an "otherappropriate means" it does not provide for tracking resolution of comments asrequired.


Finding No. 11

Valid records reviewed at the training records area list only 30.3% of the 79people, involved in SCP production, as having read PMPM 8-111, Revision 0. PMPM1-108, Revision 1 states that this procedure (8-111) is applicable to thepreparation of all parts of the SCP.

Finding No. 12

Revisions to the SCP File Index are not being approved by the Licensing DepartmentManager as required in PMPM 10-103, Revision 0.

Finding No. 13

An internal letter addressed to personnel in the Licensing Department requested SCPrelated documentation to be forwarded to the SCP Files Coordinator withoutidentifying what this consisted of. No written direction has been given anyone -outside of Licensing what to collect or to whom to send it.

Observation A

There is no approval log to show who has approval/acknowledgement authority forDOE-HQ; DOE-RL, Rockwell, and other entities for the various forms used'informulation of the SCP. Many signatures/initials are illegible and do not conformto BWIP requirements for legible records..

Observation B

, There is no mechanism to assure that authors incorporate contentious comments withwhich they strongly disagree even though those comments have been elevated throughthe accepted approval cycle.

PERSONNEL CONTACTED:

H. Babad Principal Scientist, Systems Engineering DepartmentS. K. Baker Engineering Aide, SCP Production GroupP. R. Clements Sr. Engineer, SCP Production Group0. L. Duncan Staff Engineer, SCP Production GroupS. J. Eckert Administration Specialist, Project Qualification and TrainingG. C. Evans Staff Engineer, Systems Engineering DepartmentJ. I. Feaster Procedure Analyst, Document Control UnitE. L. Fisk Staff Engineer, Repository Design and Development GroupL. J. Garvey Sr. Engineer, SCP Production GroupD. I. Herborn Principal Engineer, Licensing Department

I . .

AUDIT REPORTNO. EWIP-IA-87-004PAGE 5 OF 5

J.W.G.B.C.R.L.R.G.L.

K W.R.C.R.J.M.C.

A.J.W.M.L.J.K.K.G.C.

K.S.A.C.J.R.

HoogendooriHotarekJacksonJohnsonKoskiLandonMadayOttePennyPrestonProskRamsgateRansomSingerSonnichsenWagnerWilson

Administrative Coordinator, Operations and TestManager, Records Management UnitDirector, Science and EngineeringLicensing Analyst, SCP Production GroupLicensing Analyst, SCP Production GroupManager, SCP Production GroupForms Designer, Technical PublicationsClerk, SCP Production GroupSr. Engineer, QA Program Administration UnitEditor, Technical PublicationsStaff Engineer, SCP Production GroupManager, QA Program Development UnitAdministrative Coordinator, Science and EngineeringPrincipal Engineer, SCP Production GroupManage, Systems Performance Assessment GroupClerk, SCP Production GroupEngineering Aide, SCP Production Group

- ~ ~ ~ ~ ~ ~ ~ ~ S . :-.....; -.. ;-.

The following attachments are an integral part of the Audit Report:

AttachmentAttachmentAttachment

ABC

Pre-Audit and Post-Audit Attendance SheetsAudit Finding ReportsAudit Observation Reports

ATTACHMENT A

PRE-AUDIT AND POST-AUDIT

ATTENDANCE SHEETS

.. .. -.

AI TAlIr,-rArESllr.+;'- ';'

A. A7TV-DED PRE-.AUDIT CO';FEV'clCE . .................. j_ 2. .

B PER.SG-%NEL CONTACTED DURING AUDIT

C. ATTEND'CEO POST-AUDIT CONFEnlENCE ...

AA a

2.

�

* 5. � j /io.-rv-�cY�... N. s�

7.

B.

9.

'0.

.1.

7.

*1 ORGANIZAriON TITLE- t

/,) /--, - L, /I PA-', I., , j,1 .;, I- . _d

L.1--,- --

I I- .4 Y -��.-- -

a

j2./ '-Z ,ra ~7'C Iee4.

Asg. _

I-.

3 l;, t i. ! 'I k

. I w,

_ ' _ _ aY ~-,o.

I I ~C-A : l

.Z , , \ ~ %:,Ir ~.

.__. _-

+

1 13.

I.4.

_

I5.

16.I

.17.

_____ T _______

_________ I ___________

____________ I _______________

*1 __________________________________________________

_________________ I _____________________________________

__ .

-0I

,.O.

21.

22.

23.

,.4.

I;L-

;5.

tsit _ .! IC. _rm 41C' _: _ _c:Cn *I -* IdicteA, B. or C as applicable

Rockwell Hanford Operations.Basalt Waste Isolation Prboject AUDIT ATTENDANCE SHEET

AUDIT NO.

I 1wI P-TA - 7-004-DATE TIME

A. ATTENDED PRE-AUOIT CONFERENCE .....................

D. PERSONNEL CONTACTED DURING AUDIT

C.' ATTENDED POST-AUDIT CONFERENCE ................... 4-u7-&-7

NAME | ORGANIZATION TITLE

2.~ t 8. 'l i ii __/_-_-________:

.ti.-Ae -- f~v\f t

11.C1A,-P ;

13.

4. To

15.

17.

20.

21.

22 _

24~_. I _ _ _ ___ _.

.:-l - . ...

: . - -:

__5 _ ___________c____ I _

* *fr,84#-%4 0 o .- e, % 0 :_.

ATTACHMENT B

AUDIT FINDING REPORTS

ROCKWELL HANFORD OPERATIONS- BASALT WASTE ISOLATION PROJECT

AUDIT FINDING REPORT

Page 1 of 2

Responsible Organization Licensing Department Audit No. BWIP-IA-87-004

Location 345 Hills St./3000 Area Finding No. 01

Stop Work Order Issued yes no X Date 6/17/87

Stop Work Order No. N/A Auditor D. D. Dorsey

REQUIREMENT(S)/REVISION

RHO-GM-MA-2 Standard Requirements and Procedures 15-01 Forms Administration Rev. 0 Part 4.4Using Department "Using department is responsible for: coordinating new or revised formswith all impacted departments and obtaining approval for use...

RHO-BW-MA-17 PMPM 8-103 Rev. O'Part 3.8 Ouality Assurance Records "...Any records that meetone or more of the following criteria shall be maintained as lifetime records... Records usedin support of site selection, site nomination, site characterization..."

RHO-BW-MA-17 PMPM 8-105 Rev. 1 Part 6.1 Recording Data "1. Record data in black ink (pencilis not acceptable) on clear (i.e. mylar) or white paper whenever possible... 2. Recorded datashall be legible when reproduced with any media to the fourth generation.'

FINDING: - -

Official records in the Review Comment Record file include unapproved forms, blue ink, redi' Nink, hand written comments, pencil entries, pink, blue, green, and goldenrod paper andillegible handwriting. More than 90% are unacceptable as Quality Assurance Records by one ormore of the above criteria.

Response Commitment Date: 1- 3l iJ Acknowledged By: ' Date: - 1- -

FOLLOW-UP VERIFICATION Adequate Inadequate(COMMENTS)

Evaluated By: Date:

Finding Closed By Date

(Refer to audit response for basis of closure)

AUDIT FINDING REPORTAUDIT NO. BWIP-IA-87-004FINDING NO. 01PAGE 2 OF 2

"o Hand written, hand printed, typed and mechanically/electronically recorded data must beof sufficient penmanship quality and color intensity to be easily read.

RHO-BW-MA-17 PMPM 10-102 Rev. 1 Part 6.2 Senior Technical Review "'..The individual STRTReviewers transmit typed technical comments to the STRT Leader..."

- - - - -

ROCKWELL HANFORD OPERATIONSBASALT WASTE ISOLATION PROJECT


Page I of 2






RHO-QA-MA-3 Chapter 2.0 Rev. 3 Part 3.14 "...Records of the evaluation of a candidateseducation, experience and training compared to the documented requirements for the positionshall be maintained.'

RHO-BW-MA-17 PMPM 13-106 Rev. 1 Part 3.11 qualification of Personnel "Determination that theknowledge, skills and abilities gained through training and experience, as measured against

' established requirements, qualify an individual to perform a required job or task in a safeand proficient manner."

RHO-BW-MA-17 PMPM 10-102, Rev.]l Part 5.2 Reviewer Oualifications "The qualifications of theSTRT Leader and all Review Team Personnel shall be documented on a BWIP Review QualificationForm..."FINDING: - " -

There is no documented evidence that the Review Team Leader, Review Team'Personnel or Lead'Authors were "qualified", as measured against established, documented, requirements, asrequired.

Response Commitment Date: Acknowledged By: Avw.La~_ Date: C-r7-£


Evaluated By: Date:



AUDIT FINDING REPORTAUDIT NO. BWIP-IA-87-004FINDING NO. 02PAGE 2 OF 2

RHO-BW-MA-17 PMPM 1-108, Rev. 1 Part 6.2.1 Tnitial Text Preparation " ...A technically

qualified Lead Author will be assigned for each chapter of the SCP..."

-- L i



Page I of 1



Stop Work Order Issued yes_ no X Date 6/17/87



RHO-BW-MA-17 PMPM 8-111 Rev. 0 Para. 3.2 SCP Guidance Manual "The SCP Guidance Manual is acollection of pertinent Rockwell, DOE, Nuclear Regulatory Commission (NRC) and regulatoryguidance documents that is maintained and controlled by the Licensing Department.

r0INU, -

There is no documentedDepartment to maintainusers have the current

evidence that aand control therevision.

Document Control System is in place in the LicensingSCP Guidance Manual in a manner which assures that

Response Commitment Date: 1- 31- U1 Acknowledged By:e Date: 6 -7-f


Evaluated By: Date:



- - - -



Page l of I


Location_ 345 Hills St./3000 Area Finding No. 04




RHO-BW-MA-17 PMPM 10-103 Rev. 0 Part 5.2 Site Characterization Plan Record Hard CODY File "Ahard copy of the Administrative Record will be maintained at BWIP by the SCP.FilesCoordinator and copies will be forwarded to the U.S. Department of Energy-Richland OperationsOffice on request. The SCP record hard copy file will be maintained and protected as in-process records in accordance with PMPM 8-115."

FINDING:

The record hardrequirements of

copy of the Administrative Record is not being maintained per thePMPM 8-115.

I :, ,r, -. .,7.- . --:

Response Commitment Date: Acknowledged By:�

Date: C-/7-5i

FOLLOW-UP VERIFICATION Adequate. Inadequate(COMMENTS).

Evaluated By: Date:

Finding Closed By, Date.


-

ROCKWELL HANFORD OPERATION 'BASALT WASTE ISOLATION PROJECT


Page I of 1






RHO-BW-MA-17 PMPM 8-101 Rev. 1 Part 3.2 Outgoing External Correspondence 'Refers to allwritten communications directed to organizations, government agencies or individuals outsidethe Integrating Contractors (IC) organizations."

* RHO-BW-MA-17 PMPM 8-101 Rev. 1 Part 4.3 Outgoing Correspondence 'All outgoing correspondencewill be signed per RHO-GM-MA-2 Procedure 14-06.1. Deviation from this policy is not

- authorized, with the exception of those individuals who have been given signature authorityby the U.S. Department of Energy - Richland Operations Office (DOE-RL).0

FINDING:

he Comments fromDOE-RL and HQ

reviewers (RCR's) and copyright permission forms are regularly transmitted to"in an informal manner by Licensing Personnel.

Response Commitment Date: -'31447 Acknowledged By: Artl�� Date: X -/7- F

FOLLOW-UP VERIFICATION Adequate Inadequate.(COMMENTS)..

Evaluated By: Date:





Page 1 of 1

Responsible.Organization Licensing Department Audit No. BWIP-IA-87-004





RHO-BW-MA-17 PMPM 8-111 Rev. 0 Part 6.1 Original Text Development "...The TCC reviews thedraft against the SCP Text Acceptance Criteria."

FINDING:

There is no documented evidence that this review is being completed.

Response Commitment Date: 7-31-t[7 Acknowledged By: Date: 4-/7 4


Evaluated By: Date:



4-

I"I.ROCKWELL HANFORD OPERATIONSBASALT WASTE ISOLATION PROJECT


Page l of 1


Location 345 Hills St./3000 Area Finding No. 07Stop Work Order Issued yes noX Date 6/17/87



RHO-BW-MA-17 PMPM 8-111 Rev. 0 Part 6.3 Text Verification "The TCC forwards a copy of theControlled Draft to the Lead Author for a final accuracy check."

FINDING: . -;.

The TCC forwards the draft at the same time as general distribution not in a separate prior-step as required.

NOTE: Also see 6.3.1, 6.3.2, and 6.4.

Response Commitment Date:

FOLLOW-UP VERIFICATION(COMMENTS)-.

A7 - e u a t e _

Adequati_

Acknowledged By:

Inadequate -

Date: ,-l7.S

Evaluated By: Date:

Finding Closed By. Date


ni l

ROCKWELL HANFORD OPERATIO '?BASALT WASTE ISOLATION PROJECT


Page 1 of 1




Stop Work Order No. N/A Auditor D. D. Dorsev


RHO-BW-MA-17 PMPM 8-111 Rev. 0 Part 6.5.2 Reference Provided and Part 6.6 ReferenceDuplication

6.5.2 Reference ProvidedCoordinator forwards oneDepartment SCP Reference

'If two copies of the reference are provided, the Referencecopy to Data Management, and places one copy in the LicensingFile."

I

6.6 Reference Duplication "Data Management coordinates microfilming and duplication of thereference, and stores the completed reference sets (hard copy and microfiche) until requiredfor distribution.* -

FINDING:.

Reference is made to an organization calledthe Basalt Waste Isolation Project (BWIP).

"Data Management', no such organization exists at

Response Commitment Date: Acknowledged By: Date: 4 -17-


Evaluated By: Date:



I e- -



Page 1 of 1

I

Responsible Organization Licensing Department Audit No. BWTP-TA-87-004





RHO-BW-MA-17 PMPM 10-103 Rev. 0 Part 6.3.1 Document Transmittal "The SCP Files Coordinatorcompletes a CTP transmittal and attaches it to a copy of each group of applicable documents,as required, in accordance with PMPM 8-113. The documents are then transmitted to BRMC formicrofilming per PMPM 8-103.'

FINDING:

Documents are not being submitted per this procedure.

Response Commitment Date: - 1 l- Acknowledged By: Date: 6 -17-

FOLLOW-UP VERIFICATION Adequate Inadequate(COMMENTS)-.

Evaluated By: Date:



I



Page_1 ofjL






RHO-BW-MA-17 PMPM 1-108 Rev.. 1 Part 6.2.1 Initial Text Preparation "...each chapter/sectionwill be subjected to a small group review by DOE-RL, DOE-HQ and PNL representatives.Comments from these reviews will be addressed by the lead author and other contributingauthors...'

RHOiBW-MA-17 PMPM 10-102 Rev. 1 Part 5.1 Review Comments 'All comments shall be recorded onkJ SCP Review Comment Sheets (or other appropriate means) that documents concurrence with

comment dispositions. The name, organization, and department of the reviewer(s) should beincluded on the form."-

FINDING:

Comments from the smallrequired.

group review were not documented on SCP Review Comment Sheets, as

Response Commitment Date: ? - 3I- 7 Acknowledged By: C9�� Date: 714


Evaluated By: Date:

Finding Closed By. Date


Vr

. .. j


AUDIT FINDING REPORT'

Page_ 1 of_ 1I



Stop Work. Order Issued yes no X Date 6/17/87



RHO-BW-MA-17 PMPM 1-108 Rev. 1 Part 6.2.1 Initial Text Preparation "The preparation ofinitial SCP text will be accomplished in accordance with PMPM 8-111. Which establishes theresponsibilities of all participants as they relate to SCP text'development includingoriginal writing, word processing, editing, and control of the SCP text. In addition, thisprocedure identifies the interfaces between BWIP authors, Licensing Department staff, andTechnical Publications staff. The requirements of this procedure are applicable to the.preparation of all parts of the SCP."

FINDING: a- ; - -'

Only 30.3% of the 79 persons listed as involved in the preparation of the SCP have valid:evidence of having read PMPM 8-111. The PMPM 8-111 is not included on the required readinglists of a majority of those persons employed in departments other than licensing.

Response Commitment Date: '7- 3147. Acknowledged By: Date: -


Evaluated By: Date:



ROCKWELL HANFORD OPERATION 8BASALT WASTE ISOLATION PROJECT


Page 1 of 1



Stop Work Order Issued yes no X Date- 6/17/87



RHO-BW-MA-17 PMPM 10-103 Rev. 0 Part 5.1 Site Characterization Plan File Index "...Revisions: to the SCP File Index will be proposed to the SCP Files Coordinator by a Rockwell employee

that is involved with preparation of the SCP. All revisions must be approved by theLicensing Department Manager prior to implementation..."

FINDING:.

Revisionsrequired..

File Index-are not beingto the SCPapv b t -n Deprtm Mange .as

approved by the Licensing Department Manager a s

Response Commitment Date: 1- -3 / 7 Acknowledged By: Date: 6-i1- j


Evaluated By: Date:



rf

* -ROCKWELL HANFORD OPERATIONS4 * 'BASALT WASTE ISOLATION PROJECT


Page I of 1

Responsible Organization Licensing Department Audit No. BWiP-IA-87-004


Stop Work Order Issued yes- no X Date 6/17/87

Stop Work Order No. N/A Auditor D. D. Dorsey -


RHO-BW-MA-17 PMPM 10-103 Rev. 0 Part 6.1.1 Document Identification '...The LicensingDepartment Manager identifies existing SCP related documentation and correspondence andrequests the SCP Files Coordinator to obtain copies.

RHO-BW-MA-17 PMPM 10-103 Rev. 0 Part 6.1.2 Document Acquisition "...The Licensing DepartmentManager directs all group managers to forward copies of SCP related documentation and

v-" correspondence to the SCP Files Coordinator. All other department managers involved in thepreparation, revision and publication of the SCP, direct that group managers forward copies.of SCP related documentation and correspondence to the SCP Files Coordinator...*-

lINUINGi: - . .- - ;

There is no documentary evidence that "SCP related documentation' has been adequately'.,identified to allow the SCP Files Coordinator to obtain copies, or that department and groupmanagers, outside the Licensing Department have been directed to forward copies to the SCPFiles Coordinator.

Response Commitment Date: 7- 5i-f7 Acknowledged By: A A , Date: G-I7-E


Evaluated By: Date:



! ' -Af

ATTACHMENT C

AUDIT OBSERVATION REPORTS

- -' : ~:w a , i: :, ;.- t �

- - -


AUDIT OBSERVATION REPORT

Page I of 7


Location 345 Hills St./3000 Area Observation No. A

Date 6/17/87-

Response Rev. No. -

OBSERVATION:

I Many Review Comment Records and other documents were reviewed in the course of the audit.These require various approvals and acknowledgements which primarily consist of initials orsignatures. There is no approved signature log to show who has authority, from the variousentities, to sign approval or an example of that persons signature/initials to verify thecorrectness of the approval. Also many of the signatures/initials are illegible or

i unintelligible and need to be made to conform to BWIP requirements for legible records.

Response Required - yes X no_ Auditors D. D. D

Coimitment Date For Resoonse:7- 31- Acknowledged By:OBSERVATION RESPONSE:

Iy , :Dorsev -- . Date: .6L7187

Date! C -i 747

Commitment Date For Completion: Prepared BY: Date:RESPONSE EVALUATION: Adequate Inadequate-

Co~wents:

Evaluated By: Date: Lead Auditor: Dates

FOLLOW-UP VERIFICATION: Adequate Inadequate

Coaments:

Evaluated BY: Date:

Observation Closed By: Date:_

i

.. * :

- 40

ROCKWELL HANFORD OPERATIONSBASALT WASTE ISOLATION PROJECT.

AUDIT OBSERVATION REPORT

Page 1 of 1


Location 345 Hills St./3000 Area Observation No. B

Date 6/17/87

Response Rev. No._

OBSERVATION:

Several 'contentious, coomments have been identified in the reviews conducted to date. Whilethese comments have been handled in the manner prescribed by the procedures, many of themshow on the logbooks as open from as long ago as August of 1986. This is due in some part toauthors being strongly resistant to incorporating'statements that they disagree with eventhough a committee of their peers voted to accept the comment. There needs to be a mechanisiin place to follow up these contentious comments to assure their *timely' incorporation.

:

.' . .t j :.,.~~ -~ ! '';- ' 'AE't

Response Required yes .fno i-+@ Auditor: 0.

Commitment Date For Resoonse: 1-3147 AcknowledgedOBSERVATION RESPONSE:

D. Dorsey - -

A - _

,. I . I ,_-

Date: 6/17/87 `-

Date:- 64-7-7vat * 4 J -

*

Commitment Date For Completion: Prepared BY: Date:RESPONSE EVALUATION: Adequate Inadequate

Comments:

Evaluated BY: Date: Lead Auditor: Date:

FOLLOW-UP VERIFICATION: Adequate Inadequate

Conments:

Evaluated By: Date:

Observation Closed By: Date:_

I

- -

te- W

*o 4,




Location_ 345 Hills St./3000 Area Finding No. 11




RHO-BW-MA-17 PMPM 1-108 Rev. 1 Part 6.2.1 Initial Text Preparation 'The preparation ofinitial SCP text will be accomplished in accordance with PMPM 8-111. Which establishes theresponsibilities of all participants as they relate to SCP text development includingoriginal writing, word processing, editing, and control of the SCP text. In addition, thisprocedure identifies the interfaces between BWIP authors, Licensing Department staff, andTechnical Publications staff. The requirements of this procedure are applicable to. thepreparation of all parts of the SCP."

FINDING: -. -.I,. r.. . .

Only 30.3% of the 79 persons listed as involved in the preparation of the SCP have validevidence of having read PMPM 8-111i The PMPM 8-111 is not included on the required readinglists of a majority of those persons employed in departments other than licensing.

Response Commitment Date: '72-,3 Acknowledged By: Date: _-i1-7g

FOLLOW-UP VERIFICATION Adequate- Inadequate(COMMENTS)

Evaluated By: Date:



ROCKWELL HANFORD OPERATIONS- Page I of IBASALT WASTE ISOLATION PROJECT




Stop Work Order Issued yes no X Date 6/17/87-

* Stop Work Order No. N/A Auditor D. D. Dorsey


RHO-BW-MA-17 PMPM 10-103 Rev. 0 Part 5.1 Site Characterization Plan File Ihdex "...Revisionsto the SCP File Index will be proposed to the SCP Files Coordinator by a Rockwell employeethat is involved with preparation of the SCP. All revisions must be approved by theLicensing Department Manager prior to implementation..."

FINDING:.

Revisionsrequired.

to the SCP File Index are notb e. v b

being 'approved by' the-Licensing DepartmentMa agr'. s.

Manager as

Response Commitment Date: l7 - 5147 Acknowledged By: Date: 6-0- f;

FOLLOW-UP VERIFICATION Adequate Inadequate,(COMMENTS)

Evaluated By: Date:


(Refer to audit response for basis of closure).

S. *. 0e

v -

4- 11 -

L



Page I of 1

Responsible Organization Licensing Department Audit No. BWiP-IA-87-004



Stop Work Order No. N/A Auditor D. 0. Dorsey


RHO-BW-MA-17 PMPM 10-103 Rev. 0 Part 6.1.1 Document Identification "...The LicensingDepartment Manager identifies existing SCP related documentation and correspondence andrequests the SCP Files Coordinator to obtain copies.

RHO-BW-MA-17 PMPM 10-103 Rev. 0 Part 6.1.2 Document Acquisition I...The Licensing DepartmentManager directs all group managers to forward copies of SCP related documentation and

_J. correspondence to the SCP Files Coordinator. All other department managers involved in thepreparation, revision and. publication of the SCP, direct that group managers forward copies.,of SCP related documentation and correspondence to the SCP Files Coordinator...

I:t .- - ; ~ W :- -:

FINDING: . ..;....-. ;

There is no documentary evidence that NSCP related documentations has been adequatelyidentified to allow the SCP Files Coordinator to obtain copies; or that department and groupmanagers, outside the Licensing Department have been directed to forward copies to the SCPFiles Coordinator.

Response Commitment Date: 1- 31-f Acknowledged By: Date: FOY7-_g


Evaluated By: Date:



? - v- Hi-DI)R- /

Xt -. - /

f~ WM DOCK~ET CONTROLCENTER

"87 OCT 13 IMO:28

WM R> Fild

tstobution: ,

tRttum to WM. 623-SS)

F&. &A

WMl irojet -/° -Docket No.

PDR~YLPDR

-V IUOR 10,h

Imt -io .,I pled) .

;

v \9

/ iV)

I

- 7,q/ e,?