ML20034H251

Partially Deleted Secy Paper,Discussing Petition to Review Resumption of Construction at Marble Hill

ML20034H251
Person / Time
Site:	Marble Hill
Issue date:	05/01/1981
From:	Malsch M NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
Shared Package
ML18058B973	List: ML18058B972 ML20030B346 ML20031C827 ML20032A269 ML20033D367 ML20033D368 ML20033D369 ML20033D370 ML20033D371 ML20033D372 ML20034H176 ML20034H184 ML20034H207 ML20034H244 ML20034H247 ML20034H249 ML20034H251 ML20034H258 ML20034H273 ML20034H334 ML20034H484 ML20034H538 ML20034H550 ML20034J038 ML20034J051
References
FOIA-92-436 2.206, SECY-81-279, SECY-81-279-01, SECY-81-279-1, NUDOCS 9303160259
Download: ML20034H251 (30)

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SECY-81-279 ADJUDICATORY ISSUE (Affirmation) i For:

The Cc==issioners l

Fren:

Martin G. Kalsch Depucy General Counsel

Subject:

FETITION TO REVIEW RESUMPTIO!! OF CONSTRUCTION l

AT MARELE HILL

-Purpose:

6Y-To reconnend L

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s Eiscussion:

Save the Valley has petitioned the Ccn-ission to review a March 27,.1961 Order issued by the Direc-tor of Inspection and Enforcement-permitting the resunption of construction at Marble. Hill.-

Save the Valley questions whether the' Director has abused' i

his discretion for the.following reasons:

i 1.

Independent engineering consultants.to the NRC have not issued a final report en the existing concrete at Marble Hill; 2.

Cencrary to an alleged cennitrent by' Region III, Save the-Valley has not had an cpportun-ity to review and connent en the final version of the consultant's repcrt to NRC before resump-tion of construction; 3

The report prepared by the consultant to the applicant does not satisfy the pre-determined criteria for testing the cuality of concrete at Marble Hill because of alleged statistical inadequacies in the consultant's methodology;

Information in this record was de!cied and in accordance with the Freetm of !aformation Act, exemptions

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The Director permitted the resumption of-work l

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without first briefing the Conmission or wait-

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ing at least five. days after such a briefing i

as-he was instructed in the Commission's Order i

of March 13, 1980.

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Sheldon L. Trubatch, OGC 634-3224

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PDR FOIA CILINSK92-436 PDR 1

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I-J D.5 F.ec er:nendation :

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. s Martin G. Malsch Deputy General Counsel Attachments as stated i

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s Commissioners' comments or consent should be provided directly to the Office of the Secretary by c.c.b. fionday, May 18, 1981.

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Commission Staff Office comments, if any, should be submitted to-the Commissioners NLT May 11, 1981, with an information copy to the Office If the paper is of such a nature that it requires of the Secretary.

additional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.

l This paper is tentatively scheduled for affirmation at an open meeting during the week of May 26, 1981.

please refer to the appropriate

' Weekly Commission Schedule, when published, for a-specific date and j

time.

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h BEFORE TiiE I."JCLEAR PEiidLATO3i C0".I*ISSICI:

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I Comnissioners, Joseph I".

Hendrie, Chairman, Peter A.

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Victor Gilinsky J oh:

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OF I!1DI AIIA, i:AR3LE IIILL liUCLEAR j

F O'.-lER P L/.!I", D D 'KEI IJOS. 37:1 50-546 A!;D S!!J 50-547 -

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Comes now Save The Valley, by its attorney, and for cause of i

t Save The Valley's Petition To The Commissioners'To Review The NRC la' March 27,1981 Order To Resume Construction at Marble Hil'1 ' states:-

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That en or about March 27, 1981, the NRC acting by'31nd

nrcu h L'.::or Stello, Df. rector of Inspection ana Enfcreement, o

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'-lasning ton, D.

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(hereinafter called Director), lifted.the Au us:

u 15, 1979 Drder ',cnfirming Suspension of Construction to the-Publ.c Service Company of Indiana.

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That there has been approved by the Director in con Nncticn i

ui:h Save "he Valley, Ine pe:1:ioner herein, an agreemen to al cu an

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independent examination of the existin concrete at Marble lilli ano an o

e::a aination of the report' submitted by the licensee as preparec by Sargen: L Lundy, Repor: SL-3753, 11-20-79,

" Evaluation of-In-Place

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' Concrete, I:arble Hill Genera:In Statien, Units l'& 2"; a:-the f

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con:1usion of the review, Ine con uitants were to pro zide ' written

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findin s and conclu ions which address the adequacies of the. licensee'l a

investigation and repairs relative to problems found-ingthe fielc after.

ccncrete placement," and 1'i'" provide written findings and conclusiens l

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addressing the adequacy cf the repaired s:ructurai or expected streng:nij I

reduc tion," Scope' For Civil-Struc tural Consultant Supcort OnLiiarble-

. i Hill dated liay ' 1, - 1980, The ImC, Division of Inspection' add Enforcement;!

- i Washing cn, D.C..

attached hereto and entitled Exhibit "1".

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That the :30, Divisicn of Inspection and Enforcement, ' Chicag;,

advised orally that a written report of the independen; engineers.would ;

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- f be submitted to Save The Valley; that Save The Valley's engineering t

6 consultant would be privileged to comment thereon, either by mail or'

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e a meeting of the independent'enginee.I personally in Washington, D.C.,

at the Save The Valley engineering consultant (presumably with a Save The. !

'la. ley representative) and the !!F.C.

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Tha: to Ine petitioner's knowledge, there has been provided no written findings and conclusions which' address the adequacy of he q

. licensee's investigation and repairs relative to problems found in the.

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field after concrete placement; to the petitioner's knowledse, the t

consultants have nc provided signed written findin s and concluslons u

i which address the question of adequacies of the repaired structures 'cr.

l expected strength reduction and have offered no findings concerning

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poracity in said ccncrete.

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5 That the. petitioner questions whether. Victor Stello-the.

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Jirre:or of Inscection and Enforcement. Washington, D.C..-has abused j

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ut uiscreticn in lif tin the /.agus; 15, 1979 order confirmins suspens.

a of construction without havins. complied with subparagraph four (4)-

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herein.

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Tha: the URC Divisien of Inspectica and Enforcement, has sta:t; further that Repor: SL-3753, suora, should include therein:as its criteria that the concrete quality of' internal. concrete in structures-at Marble Hill shall meet the'strue: ural integrity; criteria of 95%

-j reliability and 95% confidence level; that on or about March 4, 1981,-

the Save The Valley engineer submitted Exhibit "A" to the URC, Region. j III with copies to the Director and the two independent engineers; saic j Exhibit "A" questioned whether the NRC had actual reason to believeL ha-l, said test criteria had been met and/or exceeded.

That on: March 26, 19E the petitioner responded to a letter of Victor Stello dated March _20,

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1981 and also enclosed as Exhibit "B".

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That as par: of a certain March 13, 19EC Memorandun And Order _ i the Commission ordered the Director to "brief'the Co==1ssi:i by the URC, prior to lif ting the order ' suspending construction _ at Marble Hill", 'emt "in any even not (to allow resumption of construction) earlier than five (5) days after the briefing".

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That Save The Valley has standin and a cognizable interest _c:i s

Save _The' Valley has been adversely affected byithe actions of,the j

Director, en March 27, 1981, and prior there o if a briefing has been held before the Commissioners and no notice given to the peti:icner.

herein of said briefing.

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That, further, Save The Valley's interest.has been adversely ri affected by :he far: tha: the Director has ra^ted a resunp;icn of-o t

work order without having received the_ signed written findin s and l

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r conclusions of the independent. engineers; further, the Director of

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concrete placin; bercre alicwing Save The Valley's engineer tinr :o 4

revie.: the independen: enL;ineers ' fir.al' written report.

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That 20 days have not elapsed.since the date of the Director

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of Inspection and Inforcenent's decision.

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Save The.'V'lley respectfully requests-thc:

f Fcr the above reasons, a

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he ::30 Cc :missioners revie./ :ne March 27, 1951 decision ' of Victor j

to determine if he has abused-his discretion under 10 CFR 2.206 I

Stello,

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(c)(1) and other relevant sections of the CFR, and~for all other proper-relief in the premises.

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Commissioner Bradford in re Public Service Conpany of. Indiana, 1

Me=crandum And Order, dated March 13, 1980 in his dissenting opinion sta:ed:

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The quality assurance and quality control (CA-QC)~

j progra-is suppcsed 20 ascure that the plant is built l

accorcint, to its design.

I f _ the CA-Ct., pregram fails, the l

plan tecones a potential thren: to the public health and l

safety, for IRC's regula:ory decisions assume the plan: is l

built according to its design

. IIRC does not normally monitor nuclear power plant construction in great detail.

l Incread, !!RC relies primarily on the licensee and their l

contractors to assure the GA-CC progra-is workin 7 AEC_7, j

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(T)he ::RC has found i difficui: to supper:

a-civil penalty sanction for CA-1C violations because of the l

general nature of construction permit and QA prot, ram j

requirement.

The Director of MRC's Division of Inspection and : Enforce-i ment has properly. suspended safety-related construction at the f

C~arble Hill) site pending the licensee's submission of a new l

QA-QC pro ram which will be judoed accordind to certain stated f

a-o criteria.

The issue is whether the inspec: ion effor:s in th;.s l

case and the Director's.iudgment about the proper remedy should.

I te examined in an evicen:lary proceedin Given the seriousness

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of the problems uncovered at the site and their possible i

j significance to the safe operation of the plant (a hearing) is t

potentially helpiul t.c us as a supplement to our own enforcement effort.

Additior. ally, it would allow interested citizens to i

l participate 'in assessing and determining the risks they are being told.to live with (A)t Marble Hill.

events have given' citizens some basis for concern about the' licensee ('s) commitment to their safety and about the sufficiency of NRC survei ll anc e.

l Commissioner Eradford further stated in Wiscensin Electric '?ower

.r Company, Docke t ::c. 50-266 in-an Order dated Eay 12, 1980 in dissent ir j conjunction with Commissioner Gilinsky the following concerning the l

levels of illusion involved in the URC's application.in denying hearini j jl The (:IRC ) a ency so misstates history tha: it is c

clearly either incapaole of givin an accurate accoun:

o of its own past doings or else its legal positions are being chosen after the desired result has been decided.

j the Commission's Pell Mell Retreat from i

meanin ful public inquiry in the twistin, be tween here.

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and I!arble Hill se suggests to the staff and the outside world tha: the agency is run by people living in fear of-their own citizenry.

(T)he message can only be Onat i

the DRC's priority in citizen involvement is a I

relatively low one."

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This (dissenting) opinion (would). (allow) a hearing to a group able to T.ake a reasona'le'showin c

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50.0 the acticn taken by the staff had failed in some important respect to recccy a particular safety concern.

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Tne petitioner'herein analogizes the presen: fae situation.with I

the s tated comments of Coe,nissioner Bradford with their releva.ce j

oward the presen: :arole Ei;l state of facts.

The I:RC Dire::or of

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Inspection and Enforcement has, aloeit gratuitously, prcaiced for. an independent' examination of concrete in conjunction with. he petitioner.;

i under certain stated criteria.

The Director has made a present' judgme: ;

. 1 dated : arch 27, 1981, which on the surface.would manifes: that the IIRC wanted a desired resalt, that result bclng the sa:r.e as' its prior interpretation in initially approving Report SL-3753soonafterNovemb) i 20, 1979.

i Has the stated criteria of 95% confidence with 95% reliability been met and/or exceeded?

The petitioner contends based on statistica.>

evidence that said'criteYia has not been met and,or_sufficiently.

explained to asrure the I;EC and the people of Southern Indiana anc

!!orthern Eentucky tha: the plant is built accordinb to its design and

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that the concrete is a potential threat to the public health and safe:,

i of the area.

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The !!EC 's independent ccnsulta.ts were to provide.a.;ritten findin.',

and conclusions; they were to provide an independent assessment cf'the !

of deficiencies in concrete construction; they were' cl type -and extent

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provide an independent assessment of needed repairs or remedial I

conclusions re nrding capabilities of.

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t affected s:ructures tc perfor., the intended desian fur.c ticns.

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l Director has, in cur opinion, abused his discre:lon in allowing a j

i resunp:icn of work, alle edij based on the ' EC's pcsitior prior to c

the tendering of said abcve' wri tten documentation Ic ' he public; andL l

t to the affected STV engineer.

See Task Order Mo. 2 Objections Of

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i Tasks, Page 1 of the IIRC, Division of_ Inspection and Enforcement j

included herein and made a part hereof and entitled Exhibit "C".

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This action is not intended to_ delay the proceedinss; has the 1(

t Director made the resumption orcer effective immediately, in~ essence-frustrating any attempts by Save The Valley to ~ appeal or thwart his decisioni Sharly v. NRC, No. 80-1691 (D.C. Cire. Ct.). Hovember 19 -

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1980, as reported in ERC, 12-5-80, page 1185.

Concernin6 10 CFR, Sec. 2.206(C)(1), within 20 days after the j

date of the Directors' decision, under this section that no proceeding.l r

will be instituted or other action raken in whcle or' in part the j

i Commission may on its own motion review that decision in whole or.in f

i part to determine if the Director nas aDused his discretion.

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review power does no: limit in any way the Commission's supervisory i

I power of delegated s taff actions.

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!f the Director has uranted the criainal Section-2.206_reques:

j u any further review cf Save The Valley for the purpece of nct s'lowin thereon, then the Code of iederal-Re ulations' let:er and spirit, in s

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originalOrder-f our opinion, has been violated.

It is obvious that the

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See Brr.dfcrd i

of A;6ust. 5, 1579, srantin, a hearino, i

J.ssentina opinion, in. lit e cns in Elec t ri c Pc k.? r C c. pan.. Docket :c.

50-266, dated I:ay 12, 1930, suora.

.Likewise the erantini of. a Section i

2.206 Motion of Save The Valley without n' firm commitment on the.part; t

E of the Director to carry out his stated objectives may be considered to be less than acceptiole.

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For the above reasons, the petitioner respectfully requests'the r

i NRC Commissioners to review in whole and in-part the actions of the l

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Director on March 27, 1981 to determine whether or not he has abused t

his discretion; and to rescind the Director's March 27, 1981 resumption j P

of work order, and for all other proper relief in the premises.

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THO:MS M.

DA Ili,0, A"' TORI!EY FOR SAVE j

THE VALLEi, PETITIO!!ER 3a,,, ~n.c~ r.

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hereby certiry thn: a_ copy of the fcregoine been mailed ~to the-fc110winu:

i Fe:er A. Bradford, ::R;. '. lash;n ton D.C.

20555, Certified :*all:.

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~ oseph M. Hendrie, ::P.0, '1ashington, D.C. 20555, o.cgular U.S. I:ai:.- l

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Victor Gilinsky, ::RC, 'dashin ton, D.C. 20555 Regular U.S. :: ail l

s John F.~Aherne,.I:RC, 'dashington, D.C. 20555 Regular U.S. Mail J ames - Keppler, IIRC, Roosevelt Rd.,

Glen Ellyn, Ill., _ Reg. U.S. Mai James Pope, Public Service Co. of Indiana, 10CO.E. Main St.,

Plainfield, Indiana 46168, Fegular U.S.-!: ail d

URC Docketing Section, 'dashington,

D.C. 20555, Regul ar U.S. Mail,. '

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1 1981.

postage prepaid, this 14:h day of April,-

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THOMAS M..DATTILO.

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SCOPE FOR CIVIL-STRUCTUU1 CONSULTANT SUPPORT ON MARBLE HILL h

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The scope of the work to be completed by a civil-structural engineer or group will l

include a review of the deficiencies which were found through visual observation J

such as the local honeycombing and voids to ascertain that significant deficiencies were detected.

The effort will also involve a review of the other techniques used to locate voids, discontinuities, etc., to determine if all significant deficiencies have in all probability been detected,. These

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l techniques included coring and pulse echo.

The repair procedures and repairs made as a result of the findings of the investigations ard also to be reviewed

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for adequacy.

The main basis of the consultant's review effort will be the report submitted by the licensee and its references as prepared by Sargent &.

Lundy, Report SL-37S3,11/20/79, " Evaluation of In-Place Concrete, Marble Hill Generating Station, Units 1 and 2."

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i At the conclusien of Ine review, the consultant will pre.ide written findings l

i and conclusions which addres's the ace:;uacy of the licensee's investigation and repairs reiative to proclems found in the field after concrete placement.

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consultant.will also need to provide written findings and conclusions which l

address the question of structural adequacy of the repaired structures or expected strength reduction, if such is the case.

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UNIVERSITY OF LOUISVILLE LOUISVILLE, KENTUCKY 40:08 SPEED sCIEh'nFIC SCHOOL J AMEs B RICIENRIDCE sPEID FOUND ATIoN DEPARTMENT oF CIY1L ENG1hT.ERLNG March 4, 1981 Mr. G. Fiorelli, Chief Projects Branch 2 U.S. Nuclear Regulatory Comission Region III 799 Rocsevelt Road Glen Ellyn, IL 60137

Dear Mr. Fiorelli:

During the Marble Hill meeting on February 9 and 10,1981. I informed Cordelle Williams that an analysis was being prepared as a follow-up to my letter and report to D. W. Hayes dated September 26, 1980. The analysis has been prepared by S. M. Alexander, Ph.D., PE, Assistant Professor of Engineering Management and Industrial Engineering at the University of Louisville.

A copy of Prof. Alexander's report is attached.

The objective of Prof. Alexander's analysis was to investigate the actual confidence of the SSL/ PSI evaluation study of in-place concrete at Marble Hill performed by Construction Technology Laboratories.

His analysis establishes a specification which considers the risk associated with the sampling plan used at Marble Hill involving 60 test sites.

'nherent in the S&L plan, which is intended to assure with a. confidence level of 95% that no more than 5% of the concrete volume is defective, is the assumption that no test error exists. The analysis is intended to determine the risk associated with this assumption. Thus, the probability that defective concrete will be erroneously accepted is not conjoined with the probability of finding defective concrete in the S&L plan.

This omission results in a plan that inevitably provides less than the required 95%

confidence.

The probability of test error which will result in accepting defective concrete has not been evaluated or considered by Construction Technology I

Laboratories in their report for this test program. However, there is ample evidence that error of this type exists. The following is a sumary of some factors which provide clear indication of the need to consider the probability of testing error of the type cited above.

The qualification test was perfomed on June 28, 1979 on concrete test blocks which contained several different types of flaws including representative conditions for honeycomb, cracks, air voids, and embedments.

Although no photo record is available to verify the results, the test was The witnessed by several persons including representatives of NRC.

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Mr. G. Fiorelli

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March 4, 1931 Page Two 3

conclusions of the qualification test was that the microseismic procedure was able to distinguish the several types of defects and accurately describe i

their condition.

Presumably this qualification also included the ability of the analyst to identify honeycomb and to distinguish between honeycomb and dispersed air of 1/8-to 1/2-inch diameter size.

On June 27, 28, and 29 of 1979 several tests conducted on the in-place concrete produced the following results indicating the presence of honeycomb. The results are cited in the test data supplied with Mr. Robert T. Bartczak's letter to Mr. Donald Stegemoller dated January 29, 1981.

The data represent raw r

field data and test photos in several areas at Marble Hill not included in Volume II of Report SL-3753. Revision 1.

Date Area Page No.

Grid Point Photo No.

6/27/79 1

4 B-3 8

6/27/79 2

7 A-1 9

6/28/79 8

16 A-7 No Photo 6/29/79 9

14 B-3 49 f

l 6/29/79 Rad Waste 1

C-9 1&3 t

i r

These interpretation results were changed during the February 9 & 10,

?

1981 meeting from honeycomb to dispersed air or entrapped air.

Such revision which may be appropriate for the tests leads to serious doubt

{

concerning the accuracy of the qualification test..No matter how the l

4 responses were interpreted at the time of the qualification tests, it would appear reasonable to expect that a consistent basis for interpreta-tion was being applied over the three-day period of June 27-29, 1979.

j A cnange of definition with respect to the test results for in-place con-crete may also be interpreted as a corresponding change in the interpreta-I tions applied during the qualification tests. Then how are we to interpret the difference between a honeycomo reflection and dispersed air in the l

qualification tests vis-a-vis the field tests.

No photographic data exist in the qualification tests record, and what record does exist is uncertain l

l with respect to size of defect and corresponding reflection signal.

Other situations involving interpretation of wave reflections also raise concern about the need to consider test error.

For example, on July 6,1979 a test reported in Area 16 on pages C-43, photo 61 of Volume II of Report SL-3753, Revision 1, indicates a discontinuity. The field notes j

for the test report honeycomb, separation and entrapped air. The un-j certainties of the definitions being applied require that some provisicn be made to evaluate the probability of test error.

l

?

l Other situations involving different thicknesses of wave reflections that are termed discontinuities raise the question concerning extent of 1

C i

-- l

Mr. G. Fiorelli March 4, 1981 Page Three the opening.

An example of this is in connection with tests of area 50 l

reported on page C-160 of Volume II of Report SL-3753, Revision 1.

Photo 289 reports discontinuities for two wave reflections in which the space for one is twice as wide as for the other.

Further, the member thickness is 54 inches, making the larger reflection about 2 inches wide.

When these considerations are applied to the S&L sampling plan the result is that the probability of test ermr must be considered.

Applying equation (c) in Prof. Alexander's report (typical results are given in the acco:rpanying table) for a test error of 15", with 60 samples the confidence level will be 92*e rather than 95% as required by NRC.

Actually, there is reason to believe that test errors may be greater than 15% resulting in a confidence level less than 90%.

Since no qualification test data are available to evaluate the test error to be applied, it is recorr enJed that such an evaluation be made.

A series of concrete test specircens with various types of flaws should be tested with appropriate photography to both evaluate the analyst's ability to discern differences in response signals and to identify large voids.

7 When an appropriate test error has been detemined, it may then be applied to the appropriate sampling plan to determine the number of test sites needed to satisfy a conditien of 95% confidence with more than 5% defective concrete.

Sincere i

%D/

/

se

/ Michael A. Cassaro, Ph.D., PE i

Professor of Civil Engineering jg 4

l cc:

D. W. Hayes-NRC C. Williams-NRC A. Parme R.Fam T. : 2tillo

\\

j i

l I

A This is a critique of the section " Statistical Basis for Testing Program" (Section III - Fgs, 4-8) included in r

the report SL-3753 - Revision 1.

This critique was prepared by Suraj M. Alexander, Ph.D.,

P.E.,

Asst. Professor, Engineering Management / Industrial Engineering, Speed Scientific School, University of Louisville, Louisville, KY.

l This critique addresses three main areas of the above

+

i section.

They are as follcws:

(i)

The lack of specification of risk associated with t

Statistical Quality _ Assurance Program.

t (ii)

Incorrectness of the theoretical background provided as related to the statistical program actually used.

(iii)

Possible misinterpretation of terminology.

l i

A.

DEFINITIONS t

Some standard Quality Assurance definitions are provided j

in order to clarify the use of these terms in the cri-l belcw tique which follows.

(i)

Sampling Plan - A specific plan which states j

l a) the sample sizes and i

b) the criteria for accepting, rejecting or taking another sample,-to be used in inspecting the lot.

i (ii)

Single Sampling:

Sampling inspection in which a decision to accept-or to reject is reached after i

the inspection of a single sample.

(iii)

Multiple Sampling:

Sampling inspection in which j

1

~

i

af ter each samplo, the decision may be to accept, t

to reject,oor to take another sample L;t in which there is usually a prescribed maximum number of samples, after which a decision to accept or reject is reached.

Note: Multiple sampling as defined here is sometimes called sequential sampling or group sequential sampling.

The ters multiple sampling is preferred.

(iv)

Sequential Sampling:

Sampling inspection in which, after each unit is inspected, the decision is made to accept, to reject, or to inspect another unit.

Note:

Sequential sampling as defined here is seme-times called unit sequentiai sampling.

(v)

Acceptance Number:

The largest number of defectives (or defects) in the sample or samples under con-sideration that will permit the acceptance of the inspection lot.

B.

CRITIQUE i

(i)

The lack of specification of risk associated with the Statistical Quality Assurance Procram_.

l r

In deriving the sampling plan, Sargent & Lundy Engineers (S & L) define (Np)(Ng )

r C=1-I x

n-x (1) x=0 N

(n) where they define C = Confidence level n = Sample size N = Size of population p = Acceptable maximum fraction defectives in the population.

2

"by testing a number of random They go en to state that, i

samples (n out of a population N), we can establish with confidence C that the max. fraction defective is p if the l

observed number of defectives is r."

r l

The above equation for C is infact the probability of 1

rejecting a lot of quality p (fraction defective p), when a F

single sampling plan is used with a sample sire n and accept-ance number r.

Since NRC expects the sampling plan to reject ' defective' concrete volumes 95% of the time (95%

confidence level), the presumption here is that concrete i

volumes with p% defective are ' defective.'

The above equa-l l

tion (i), which represents the probability of having more i

i than r defectives in a lot is derived 'from the Hypergecmetric distribution.

S&L uses the Binomial approximation to the 1

Hypergecmetric distribution in deriving a value for n using a value of r equal to 0.

The Binomial approximation to the I

Hypergecmetric is shown below in equation (2).

'i

}

r

($)p g

(2) x n-X C=1-I x=0 l

The above Binomial apprcximation is valid if n is small com-r I

pared to N.

5& L uses equation (2) with a value of C = 95. p =.05 i

and r = 0 to solve for n and obtains a value of n = 59.

Thev I

then suggest a sampling plan with sample sire n = 59 and l

acceptance number r = 0.

In their words, "as a first step,,

a sample of 59 areas is to be tested.

In order to establish t

with a confidence level of 951 that no more than 5% of the I

population is defective (i.e. reliability of 95 %) none of the i

3 I

b

i samples should fail the test".

If the sampling plan solocted r

was used as a single sampling plan, (i.e. Sample size n = 59, Acceptance number r = 0); it would reject a population with 5% defective 95% of the time.

In. order to understand what happens to populations with larger and fewer defective per-r centages an Operations Characteristic (O.C.) curve'must be t

constructed for the sampling plan.

As an example the O.C.

Curve shown in Figure (1), which was plotted af ter some rough calculations were made by me, detail the erobabilities of acceptance of different quality populations using a single sampling plan with n = 59 and r = 0.

1 i

t O.C. Curve Prob..,.

n=a9, r=0 of o

AO C epta nce,,g,-

t

.g.

=5, e<

e" i i j' f G 4 5 9 4 f

D%

i

__n l

I Figure 1 4

i

Thus if the sampling. plan was a single sampling plan (the i

~

equations.used to derive n are only valid for a single j

i sampling plan) the risks associated with using the plan is j

best illustrated by the O.C. Curve Figure (1).

These risks l

i have not been specified by S & L in their statistical orogram.

I i

Incorrectness of the theoretical background pro-(ii) vided as related to the statistical program actually used.

S & L's theoretical backing for its 'sanpling procedure (equa-i tions (1) & (2)) are for a single sampling plan, but at the i

f 5 & 6 of the end of the section on Methodology (See Pgs.

1 report) they state that "the sampling program is sequential in that if a defective area is encountered in the first 59 samples, the sample size is increased to a total of 93 units t

and the acceptance number is increased to 1, if another, l

defective is found the sample size is increased to 124 with 1

acceptance number 2 and so on (See. Table III-1 on pg. 8 of the report SL-3753).

No explanation is provided as to how these nt=bers are cbtained, though a quick check reveals that (1) and (2).

they are obtained frem the same two equations f

These equations as mentioned before, determine the probability of rejection of a population of fraction defective p by a l

single sampling plan of size n and acceptance number r.

However the procedure followed in the testing program is that of pseudo sequential sampling (see pages 5 and 6) no theoretical l

1 background or references is provided for this sampling pro-j I

cedure in the report.

The sampling procedure is neither a unit sequential sampling plan, (which is generally used to the number o.f samples taken to make a' decision for minimize 5

i i

l

~

cceeptance or rejection), nor is it a multiple sampling plan (group sequential; see definitions provided at the beginning of the critique).

The main point to be noted here is that the program L is not a single sampling plan hence it is suggested by S &

incorrect to derive parameters for the plan from equations since the plan is not a standard (1) and (2).

Moreover, plan and since, no references are provided the determination difficult.

In my of risks associated with the plan become i

opinion no sampling procedure for testing should be used without a proper indication of the risks associated with the procedure.

Therefore S & L should either change their test-theoretical backing for their ing program or provide correct l

sampling program and indicate the associated risks.

(iii)

Possible misinterpretation of terminoloav.

L defines a population with 5% defective as 95% reliable.

S&

In other words they state that if 5% of the concrete volumes This in-existing are defective then they are 95% reliable.

terpretation of reliability is not clear from the letter from "Public Service of Indiana will:

NRC (Exhibit 1) which states, With its contracted organizations, centinue surface and 1.

volumetric examination of existing concrete volumes to estab-lish its adequacy and test a statistical sample, representative of both congested and other concrete volumes to assure with and 95% confidence level, that concrete volume 95% reliability

=eets recuirements."

The term reliability used above is quite could for example relate to the accuracy of the ambiguous, it L has interpreted reliability to be synonomous test, whereas S &

5. requirements and hence attempted to design a sampling w'

plan which rejects populations o# 5% dOfcetivo (95% rollability

~

with according to S & L interpretation, See bottom of pg. 6) a probability of.95 (Confidence level-95%).

t t

4 4

0 7

TIIOMAS M. DA*ITILO ATToENEY AT LAU 314 EAST MAIN STETET AADi$oN, INDIANA 472SO l

Pwoks 812 2634313

!.: arc h 2 6, 1981 United States

luclear Re ulatory Cor. mission u

Region III 799 Rcosevel: Road Glen Eliyn, Illinois 60137 ATT!;

I:r. J anes G.

Keppler, Director Re:

STI; 50-546 STIJ 50-547

Dear I:

r. Keppler:

to D5. Cas.;aro dated :*arca Thank,,cu fo r your respo*ue

/0, 1981.

i'ind enc ioned :10 F.xhibit "A'

ne re.n Dr. Jac sarv 's speeific response to yvur:.

Thi.. wri;cr in conjunction with the enclosed Exhibi;

A" categorically states thstr the I!RC has not responded Oc :he

!: arch 4, 1981 letter of Dr. Cassaro and the specific s tatistical

.ind quality control ensneerint., comments therein.

!: is our poc i t ion that yeur alle ed explanations are simply incu:'ficion; o

o manifest to the I P.C ;b.t its own criteria of OM'. reliabill:y witn 9S confidence has buen met and,or exceeded by :he ';ea t.

prodran :levised cy 3c:.

• Lundy and conduc teu by For:12:.d Ccmer.:

/.ucciaticn.

In addi.icn, 1;

.<as our specific understandin tha no I.RC renponses would be made ur.: 1 there was tine to review wha; the independen e::oineers s tated in a final..tritten repor; tubjcc t to the addi;icnal input of Dr. Cassaro.

Ircn all it.d i c a:icnc. i t.

is no: necescarily corree: : hat the !;30 ha 1;>p ro ved :ne.cs:in s tand trds ar.d cri te ria pe.:1rie.111j a

ac:. out by.ne ::RC in ita ; rior orders herd.n.

Fer tha-rearon, we awal the final sr;tten reports of the independen: en ineera and the !

o c.pecific reports cf :he :,RC.

Very truly

cars, i

f s

~

f'.L% / " 2.kEl Tho:r.as ::. Dat.ilo TND,ejb I

'nclosure s?

i

\\

=

S-4

'N "e.,

e ep8

i Michael A.

Cassaro,-Ph.D.,PE Professor of Civil Engineering Speed Scientific School Dept.~of Civil Engineering 1

University of Louisville Louisville, Kentucky 40208 March 26, 1981 United States i

!!uclear Rebulatory Commission

~

P.cgion III 799 :.Osseve1t f.oad c,len F. ilyn, Illinois 60137 J

AT!!!:

r. J ames G. Keppler, Direc:or Re:

STN 5v-546 STI: 50-S47 Dear

'r.

Ecppler:

ine !:hC letter of ! arch 10, 1951 L

';a..

de:a::ed 2:A re ano: ai; Ly co:uprehennive.

o.s t of the points in my Let ter o f Jeptember 26, 1560 have t>een discussed and handled.

It is the ::aren 4 L9dl c t. '.e r o f m ine that has r.or, been comple tely ar.:rae red :n.d is.

the.ubject of this correspondence.

he ?;E mu;t rely on mic rosei.

.ri

n ' e.. : ca *...;

to de e r,.:.e if voids, neparations or honeyev::.b !. c x i s '. :n :he e s. r re..: since alt clemervable vo ld.> are e r:...dered ";urf rc.;

i ce re e defcetives".

Since the

• K h a.,

e. ;.ib t i.n e-:

.l a r.;er:a. O S:l> re l iab i l i ty w1.h 'J b - 2 en f i::: :-:.. : 3. : :., L;.:2.;cn

?.

ust be recct,ni.:ed tha: this is a pret LNistic eq;a;. n 1.a ; y i r.u no instrument. cr htc.an error as: ce.15ed wl:h

le s tati.s tical approach.

he :' arch 4 ie;.er di'.9s an acceptiu.e p rec ed. re f*: r ae c rm.n int, and in:iudin the h.2 man error

.n d the

r.,

rune:4.

o

.rrar i n.:. h e test program.

Jeveral exicp ie:, o f tr.is./pc cf e.vr.tre cited in the !! arch J 1 ' t '. e r.

For -:x.cmie. I f. hit

.crpretor declared a "honeyecr.b" t h e

.:r.e.! u,- ne : at:cd ine qua!ification tes; and the honeyco".b turr.ed.

t.. rie

.: ; mn.ficant bubbics i:. the.;cncre te. tht": there

.tp;". ira ~ 4 re rc.t.

.ible roc:- fo r -a rrc r.

I k

,*v ss. ee 7...

.e.

D I-h k

r Mr. James G. Keppler Nuclear. Regulatory Comm.

-March 26, 1981 Page 2.

'ie do not question Mr. Muenow's qualifications.. Iloweve r,

everyone is capable of making an. error.

It appears that no written qualification exists in the record at.-Narble Hill.

A qualification record must be performed to evaluate if we. have 95!6 reliability with 95;6 confidence.

~As it r.ow stands, there is certainly less than 95:5 reliability as outlined ir. ' the March 1 le er, and we believe that no-verbi Ae will crase :nat reality, only clear statist:.c.:..

Th.s.eriter avaits the fur:r.er responce of :he !!RC.

l Sincerely,

\\p...s..tu

~

,.3>. y (.x( w.. <-.

.Lunae L h.

C a t :~. aro.

?h.D..

v.T t

II/.C,.3j D P

I t

t 1

i i

i f

p b

t

,1.

Scoce cf k*ork:

4 t

t

~

Provide NRC-IE assitance as a technical consultant in the review of 1) l concrete deficiencies, known as "honeycombing," found at the Marble Hill i

facility through visual observation, 2) the pro 5 ram to determine if l

internal voids exist, 3) the repair p.rocedures, 4) the completed repairs, and 5) evaluation of the affected structures to meet the original design '

~

intene.

. - " ~ ~ ~

l

~

The effort will involve a review of the techniques used to locate voids, I

discontinuities, etc., to detenmine if all significant deficiencies have in all probability been detected.

These techniques included coring and.

~ __ t pulse echo. ^.The repair procedures and repairs made as a result of the

" findings of the investigations ard also to be reviewed for adequacy.. The

____ main -basis of the consultant's review effort will be the report submitted by the licensee and its references as prepared by Sargent &,Lundy, Report

. SL-3753,11/20/79,." Evaluation of_In-Place Concrete Marble Hill Generating --- - -

Station, Units 1 a.nd 2," dated November 20, 1979.

i 2.

Obiectives of Tasks-a.

to provide an independent assessment of the type and extenP*o?

{

deficiencies in concrete construction defined as honeycombing and/or voids _that could have safety significance; P

b.

to provide an independent assessment of any needed repairs or '

- t remedial actions; c.

to provide' independent conclusions recarding the capability of the affected structures 16 perform the intended design functions.

2.

Statscent cf k'ork:

Determine thai eny structurally sienificant honeycombing and/or z.

voids visually detectable have been located and identified.

b.

Evaluate the need for.and adequacy of the nondestructive techniques used by the licensee in the investication of possible internal voids.

If other techniques or additional investigation are neces-sary to assure structural adequacy, rec.ommendations should be provided.

This evaluation and any necessary recommendations should consider sample location and size.

i l

g

.. p.

v. 3