ML20134N992

Responds to 850726 & 0806 Requests for Termination of Overinsp Program for Reinsp of Electrical Hangers.Review Concluded Concurrence Cannot Be Given Due to Listed Reasons, Including Low Quantity of Items Inspected

ML20134N992
Person / Time
Site:	Clinton
Issue date:	08/30/1985
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Gerstner W ILLINOIS POWER CO.
References
NUDOCS 8509060100
Download: ML20134N992 (2)

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August 30, 1985 Docket No. 50-461

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Illinois Power Company 1

ATTN: Mr. W. C. Gerstner Executive Vice President i

500 South 27th Street Decatur, IL 62525 a

Gentlemen:

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.

3. NRC Inspection Report 50-461/84-37

4. Letter, J. G. Keppler to W. C. Gerstner, dated 9/17/84.

This letter is in reply to your letters of July 26 and August 6,1985, requesting termination of the Overinspection Program for reinspection of electrical hangers described in Reference 1, and HVAC ducts and supports described in Reference 2.

We previously discussed termination of the overinspection, or parts thereof, with you in References 3 and 4.

We have completed our review of your request. As discussed with members of your staff by telephone on August 14, 1985, and with Mr. Hall on August 21, 1985, we do not believe that the data and engineering analyses supplied with your requests support your conclusions. Therefore, we do not concur at this time in your request to terminate the Overinspection Program for electrical hangers or in your request to terminate the Overinspection Program for HVAC duct and duct supports. We are unable to concur.in your requests at this time for the following reasons:

1.

Inspection data for electrical hangers and HVAC items does.n.ot include the 1985 data; therefore, we cannot determine if any new trends or types of discrepancies have been discovered.

2.

The quantity of items inspected is low. Our understanding of the Over-inspection Program was that Illinois Power would verify the quality of approximately 20% of work performed prior to July 20, 1982. We are unable to determine if the sample presented is representative of the entire population.

3.

The rate of items with nonconformance per item inspected is high; therefore, more information concerning the types of discrepancies discovered and their significance is required.

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s Illinois Power Company August 30, 1985 f

Based on the telephone discussion with Mr. Hall on August 21, 1985, it is our understanding that Illinois Power believes there is adequate bases for termin-ating the overinspection in the requested areas. As stated previously, the NRC believes insufficient data and analysis was supplied with the requests to enable us to reach the same conclusion. Mr. Hall expressed his willingness to provide additional information, including 1985 data, to address the NRC's concerns.

It is our understanding that while the supplemental information is being prepared, Illinois Power is considering at its' risk, the termination of the Overinspection Program in the requested areas. We request that you document this proposal and the basis for the request.

We acknowledge receipt of your request dated August 12, 1985, to terminate the Overinspection Program for cable tray, conduit, cable, and cable terminations.

As discussed in our August 21, 1985, telephone conversation, we plan no further review of ti.at submittal at this time. We understand that you will evaluate the submittal in view of the concerns stated above.

In the meanwhile, Region III is continuing to inspect and verify as-built conditions of cable tray and conduit supports as well as HVAC duct and supports.

In addition, a preliminary review of the NCR's in the requested areas has been initiated as part of an inspection concerning the Overinspection Program.

This inspection will also review the evaluations of the discrepancies performed by Sargent and Lundy.

Thank you for cocperating with us in this matter.

If you have any questions please contact R. F. Warnick at (312-790-5575).

Sincerely,-

Original slGned by A. Bert Davis-James G. Keppler Regional Adminis'tator cc: DMB/ Document Control Desk (RIDS)

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