ML20083H540

Final Significant Const Deficiency Rept 71 Re Inadequate Review of Condition Identification & Work Authorization Forms for Reportability.Qa Procedures Revised

ML20083H540
Person / Time
Site:	Waterford
Issue date:	12/20/1983
From:	Gerrets T LOUISIANA POWER & LIGHT CO.
To:	Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
71, W3K83-2016, NUDOCS 8401130247
Download: ML20083H540 (4)

Text

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LOUISIANA ,42 oa anoNoe srn m POWER & LIGHT P. O BOX 6008 . NEW ORLEANS. LOUISIANA 70174 * (504) 366-2345

'#'PuSk'siv$NO uT December 20, 1983 W3K83-2016 Q-3-A35.07.71 Mr.rJohn T. Collins Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012

REFERENCE:

LP&L letter W3K83-1791 dated November 18, 1983 g

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Dear Mr. Collins:

I li il I;t JM - 31984 i a

SUBJECT:

Waterford SES Unit No. 3  ! \j Docket No. 50-382 L Significant Construction Deficiency No. 71 ,

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" Inadequate Review of CIWA's for Reportability" '

Final Report In accordance with 10CFR50.55(e), we are hereby providing two copics of the Final Report for Significant Construction Deficiency No. 71, " Inadequate Review of CIWA's for Reportability".

If you have any questions, please advise. .,

Very truly yours, If f T. F. Cerrets Quality Assurance Mancger TFG:CNH:VBR Attachment cc: Director Office of Inspection ( Enforcement U. S. Nuclear Regulatory Commission Washington, D.C. 20555 (15 copies) yr Tf; o /

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8401130247 831220 PDR S

ADOCK 05000302 PDR

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Mr. John T. Collins December 20, 1983

- W3K83-2016 Page'2 cc: Director s' Office of Management Information and Program Control U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. E. L. Blake.

Shaw. Pittman, Potts, & Trowbridge 1800 M Street, N.W.

Washington, D.C. 2003e Mr. W. M. Stevenson Monroe & Lemann 1424 Whitney Building New Orleans,' Louisiana 70130 bi I- _ _ _ _ _ _ _ _ _ _ , , _ , _ , , _ _ _ _ _ _ , __ _ _ _ . __ _ , _ _ _ , _ _ _

3 FINAL REPORT OF SIGNIFICANT CONSTRUCTION DEFICIENCY NO. 71

" INADEQUATE REVIEW OF CIWA's FOR REPORTABILITY" r

INTRODUCTION This report is submitted pursuant to 10CFR50.55(e). It describes a failure to properly review Condition Identification and Work Authorization (CIWA) forms for reportability. To the best of our knowledge, this problem has not been identified to the NRC pursuant to 10CFR21.

DESCRIPTION OF DEFICIENCY The CIWA form is being used for identification, documentation, evaluation,'and correction of conditions discovered at Waterford 3. CIWAs are routed through Ebasco Startup, Ebasco ESSE, or the LP&L Work Group fcr disposition and corrective action. CIWAs routed to Ebasco Startup are evaluated for reportability per the Ebasco N-23 procedure. It has been discovered, however, that CIWAs routed to ESSE and the LP&L Work Group (since June,1981) are not being formally evaluated for reportability.

SAFETY IMPLICATION Since the review of CIWAs was not properly performed, it is possible that the NRC has not been notified of some significant construction deficiencies.

CORRECTIVE ACTION To correct this condition, the following action was taken by LP&L. The Quality Assurance (QA) group was assigned the responsibility of performing an initial screening of CIWAs for reportability in accordance with QP 19.3, "CIWA Reportability Screening". CIWAs which could be reportable were transmitted to the Onsite Licensing section for the final teportability determination in accordance with NAP-117, "Idantification Evaluation, and Reporting of 10CFR50.55(e) Deficiencies".

The screening by QA was performed for all CIWAs (9550) directed to Ebasco ESSE

-(historical), CIWAs written from June, 1981 to present that were worked by the LP&L Work Group (historical), and those which were being generated on a day to day basis (ongoing). A listing of all CIWAs was reviewed to determine which CIWAs required review. Those requiring review were logged to document the review and screening determination.

The screening and review for reportability of historical CIWAs identified by the original SCD Report has been completed. It was determined that several deficiencies identified on CIWAs were reportable, however, these deficiencies had-been previously reported to the NRC and were not dependent on this review.

It can therefore be concluded that although the C1WAs did not undergo a formal rsvieu process for 1CCFR50.55(e) reportability, significant deficiencies were being identified by other means and were being reported to the NRC when discovered.

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'LONG TERM CORRECTIVE ACTION

. The mechanism by which CIWAs will be reviewed for reportability on a permanent

-basis consists of copies of CIWAs.being screened for reportability, and, if determined to be potentially reportable a formal evaluation is made and the deficiency reported if within the guidelines of 10CFR50.55(e). The guidelines of 16CFR50.55(e) and 10CFR21 have been-included in QA procedures QP 15.2 "Reportability Screening of Documents Identifying Conditions Adverse to Quality" and QP 15.3 " Evaluation and Reporting of 10CFR50.55(e) Deficiencies and Possible 10CFR21 Defects" to facilitate these revievs.

This is submitted as a Final Report.

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