ML20134L811

Advises of Position Re Applicant 850726,0806 & 12 Requests to Remove Addl Commodities from Overinsp Program.Electrical Hangers,Hvac Duct & Supports,Cable Tray,Conduit & Cable & Cable Terminations Should Not Be Removed from Program

ML20134L811
Person / Time
Site:	Clinton
Issue date:	08/27/1985
From:	Samelson A ILLINOIS, STATE OF
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8509030425
Download: ML20134L811 (3)

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ea7os M L Y A L' August 27, 1985 BY EXPRESS MAIL

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Mr. James G. Keppler Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

Illinois Power Company Requests for Concurrence to Remove Additional Commodities from the Overinspection Program Reference 1: IPC letter U-600197, Hall to Keppler, dated July 26, 1985 Reference 2: IPC letter U-600211, Hall to Keppler, dated August 6, 1985 Reference 3: IPC letter U-600215, Hall to Keppler, dated August 12, 1985

Dear Mr. Keppler:

I am writing in order to advise you of the position of the Illinois Attorney General's Office (IAG) regarding the three referenced requests of Illinois Power Company (IPC) to remove additional commodities from the Overinspection Program at Clinton Power Station. Based upon the information provided by IPC and for the reasons stated below, the IAG believes that electrical hangers, HVAC duct and duct supports, cable tray, conduit, cable and cable terminations should not be removed from the Overinspection Program at this time.

Firstly, in the referenced letters IPC has provided Overinspection Program results only as of December 31, 1984.

Data for 1985 should be provided in order to confirm that the 1984 data is still representative of current program results. In our opinion, it would be imprudent to allow deletion of commodities from the Overinspection Program in the absence of current data.

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Mr. Keppler 2 August 27, 1985 Secondly, we urge NRC to independently determine the

" safety significance" of the nonconformances identified by the Overinspection Program before concurring with the removal of commodities from the program. At a minimum, NRC should conduct a detailed review of the documents relied upon by IPC in reaching the conclusion that none of the identified nonconformances are

" safety significant". We would expect the NRC's assessment to be documented and available for our review.

In this regard, the IAG believes that special attention should be given to the categorization of nonconformances by IPC.

Two examples will illustrate the basis for this concern. In many cases, IPC relies upon the existence of future testing programs in order to conclude that a group of nonconformances are not safety-significant. Such reliance may be misplaced as was demonstrated during the CAT inspection by the failure of the electrical separation walkdowns to detect discrepant conditions.

Also noteworthy in this regard is the CAT inspection finding that work performed by IPC staff on systems and components after turnover from construction has been ineffectively controlled.

Another example is the IPC conclusion that wood debris left in cable trays presents no safety-significant condition. Yet it appears that IPC failed to consider the fire hazard that such debris might pose. Thus, we believe NRC should conduct a detailed review of the nonconformance categorizations in order to independently determine whether all implications of the nonconforming attributes have been adequately identified and addressed by IPC.

Thirdly, we remain concerned that thousands of nonconformances were undetected by the normal QA/QC program. It is significant that for a number of commodities, approximately 50% of the item inspected required the issuance of an NCR documenting at least one nonconforming attribute. The IAG believes that IPC should (1) conduct analyses to identify the root cause(s) which allowed nonconformances to remain undetected by the normal QA/QC program and (2) initiate appropriate corrective actions to address the root causes. The root cause analyses and corrective action program should be provided to NRC i and t he IAG.

l Finally, the IAG believes, based upon findings of the recent CAT inspection, that the Overinspection Program should include systems "important-to-safety" but not " safety-related".

As you are aware, the CAT inspection confirmed that there are more hardware and QA/QC program deficiencies in areas not covered by the Overinspection Program. Consequently, we believe that commodities installed in important reactor control systems that are not presently addressed by the Overinspection Program, such as the feedwater control system, should be included in the Program, especially if other commodities are removed from Overinspection.

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d- 'Mr. Kappler 3 August 27, 1985 If you have any questions regarding these comments, please feel free to contact Richard Hubbard or the undersigned.

Very truly yours, ld i Allen Samelson Assistant Attorney General Environmental Control Division AS:rsr cc: S. Zabel B. Siegel J. McCaffrey R. Hubbard