ML20136J252
| ML20136J252 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/21/1985 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Gerstner W ILLINOIS POWER CO. |
| References | |
| NUDOCS 8511250311 | |
| Download: ML20136J252 (4) | |
Text
4 f
NOV 211985 Docket No. 50-461 Illinois Power Company ATTN: Mr. W. C. Gerstner Executive Vice President 500 South 27th Stceet Decatur, IL 62525
References:
- 1. Letter, D. P. Hall to J. G. Keppler, U-600197, dated 7/26/85.
- 2. Letter, D. P. Hall to J. G. Keppler, U-600211, dated 8/6/85.
i
- 3. Letter, D. P. Hall to J. G. Keppler, U-600215, dated 8/12/85.
- 4. Letter, D. P. Hall to J. G. Keppler, U-600295, dated 10/11/85 Gentlemen:
This letter is in reply to your letters requesting termination of overinspection for electrical hangers; heating, ventilating, and air conditioning (HVAC) duct and duct supports; and cable tray, conduit, cable and cable terminations (references 1 - 3, respectively).
M We have completed our review of your three termination requests, as supplemented by additional information requested by Region III (reference 4).
In addition, we have inspected the as built-condition of the requested commodities; reviewed nonconformance report dispositions for the requested commodities; reviewed a sample of the results of safety significance evaluations performed by Sargent &
Lundy (S&L) for the requested commodities; and reviewed the status and results of NRC inspections related to the requested commodities.
Several concerns raised during our review required additional action by Region III and/or reliance on the conduct of your continuing quality assurance program to provide adequate resolution, as follows:
1.
Reference 4, page 12 discusses the basic reasons why nonconformances (NCRs) identified during overinspection of cable tray were evaluated as not significant to plant safety. According to the discussion, fif ty-nine NCRs involving dirt and debris in cable trays were evaluated as having no impact on system design capabilities. Whereas the presence of dirt and debris by itself may not impact system design capabilities, Region III has been and is concerned that foreign matter not be allowed to remain in cable trays in order to limit the possibility of damage to cable jackets and to preclude the presence of fire and dead weight loadings for which the tray system was not designed. Based on discussion with plant management at several recent NRC exit meetings, it is our understanding that your i
Quality Assurance (QA) program includes a routine cable tray monitoring program which functions to preclude the accumulation of dirt and debris in safety related cable trays.
In addition, we understand that cable trays are cleaned and inspected prior to the installation of cable tray covers and similar fire barriers.
h}
051125o311 851121 0
PDR ADOCK 05000461 G
PDH 0
1
'%'YJ "o ' @S Illinois Power Company -2.
Reference 4, page 14 discusses the basic reasons why NCRs identified during overinspection of cable terminations were evaluated as not significant to plant safety. According to the discussion, thirty percent of the nonconforming attributes in this commodity involved conductor termination errors which would have been identified and corrected during the conduct of the preoperational test program. Region III reviewed each such NCR evaluated by S&L and concurred in the S&L evaluation.
3.
Reference 4, pages 14 and 15 discuss the basic reasons why NCRs identified during overinspection of cable terminations were evaluated as not significant to plant safety. According to the discussion on page 14, eleven percent of the nonconforming attributes involved lugs that were not tightly connected to the terminal block. The S&L evaluation stated that electrical continuity was ensured because only ring-tongue type lugs were used.
According to the discussion on page 15, the majority of wrong hardware type deficiencies (which comprised ten percent of the nonconforming attributes) were mechanical compression type lugs used instead of ring-tongue lugs. These evaluations appeared to be contradictory. Based on a telephone conversation between Mr. T. P. Gwynn of my staff and Mr. J. Karr of your staff on November 8,1985, we understand that the use.of compression type lugs was limited to vendor supplied equipment; that the use of compression type lugs was permitted in those applications; and that the lugs identified as being the wrong type were not, in fact, loose.
In addition, we understand that you have recently inspected a large number (98) of vendor supplied panels for workmanship deficiencies, based on your construction deficiency report 55-85-06. According to your report, your inspections did not identify any problems related to loose terminations.
This information provided an adequate basis to resolve our concern.
4.
Reference 4, page 25 discusses the basic reasons why NCRs identified during overinspection of HVAC duct and duct supports were evaluated as not significant to plant safety. According to the discussion, engineering analysis was not required due to the revision of the design criteria subsequent to the performance of the overinspections.
Based on a telephone conversation between Mr. T. P. Gwynn of my staff and Mr. J. Karr of your staff on November 8,1985, we understand that some inspection criteria used during the overinspection of HVAC duct and duct supports had no engineering tolerance assigned, resulting in an overly stringent inspection.
We further understand that S&L Project Instruction (PICP) 068, Overinspection Program HVAC Ductwork & Hanger Acceptance Criteria, was revised to include reasonable engineering tolerances for such items as hanger location, weld size, weld length, etc. We further understand that those revised criteria were reflected on S&L drawing M14-1180 which is an approved for construction drawing. Based on this clarification, we had no further questions with regard to this matter.
Illinois Power Company NOV 211985 5.
Reference 4, page 27 provided the percentage of cable tray supports and conduit supports in the total population of overinspected electrical raceway hangers. This information clearly demonstrated that the overinspection by IP provided a representative sample of both conduit and cable tray hangers. Although the fraction of the total population of overinspected electrical hangers is low in comparison to the other commodities subject to termination request, we believe that the sample is statistically significant and, when combined with the results of Baldwin Associates field verification and 100% cable tray hanger reinspection programs, provides a high level of confidence in the quality of safety related electrical hangers.
We have concluded that overinspection of the requested commodities represented a healthy sample of each commodity; that the sample was representative of the entire safety related portion of Clinton Power Station; and that the sample clearly demonstrated the quality of plant structures, systems, and components within the scope of the termination request. On that basis, we concur in your proposed termination of overinspection for safety related electrical hangers;
' heating, ventilating, and air conditioning (HVAC) duct and duct supports; and cable tray, conduit, cable and cable terminations.
Notwithstanding the above, we recognize that your overinspection in the requested commodities did identify a significant number of nonconformances, some of which were reworked. We understand that your QA program is designed to identify and correct such nonconformances; however, we believe that you should review the overall results of your Overinspection Program to date to determine what lessons may be learned from those results. We further believe that you should use those lessons learned, if any, to improve your overall quality performance during future operation, maintenance, and modification of the Clinton Power Station.
Finally, we request that you provide Region III with the results of your review; the actions you intend to take as a result of the lessons learned; and a schedule for implementation of identified improvements.
Thank you for cooperating with us in this matter.
If you have any questions please contact R. F. Warnick at (312-790-5575).
Sincerely, l
" Original Signed by J. G. Keppler" James G. Keppler Regional Administrator cc: See Distribution RIII RIi1 I
RIII RIII Rill.[W ft'HO RRO O W w
.6 Gr/.
Gwynn Warnick Norel'ius ape illo Davis Keppler 11/1V /85 11//f/85 11/ / 85 11/M/85 11A/ /85 11/ N/85
rig
- 11 t 85 Illinois Power Company
-4 Distribution:
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII Richard Hubbard Gary N. Wright, Manager Nuclear Facility Safety Jean Foy, Prairie Alliance Mark Jason, Assistant Attorney General, Environmental Control i
Division l
H. S. Taylor, Quality Assurance Division l
i.
i
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.