ML19271A987

Responds to NRC 800515 Ltr Re Violations Noted in IE Insp Repts 50-546/80-06 & 50-547/80-06.Corrective Actions:Spec Y-2850 Will Be Revised to Delete Section 411.7A

ML19271A987
Person / Time
Site:	Marble Hill
Issue date:	06/16/1980
From:	Shields S PSI ENERGY, INC. A/K/A PUBLIC SERVICE CO. OF INDIANA
To:	Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19271A984	List: ML19271A987 ML19271A989
References
NUDOCS 8008110436
Download: ML19271A987 (4)

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PUBLIC SERVICE lbdE)![kEd/k June 16, 1980 S. W. Shields Senior Vice President -

Nucler Dhision Mr. Caston Fiorelli Docket Nos.: STN 50-546 U.S. Nuclear Regulatory Commission STN 50-547 Region III 799 Roosevelt Road Construction Permit Nos.: CPPR-170 Glen Ellyn, IL 60137 CPPR-171

SUBJECT:

Marble Hill Nuclear Generating Station - Units 1 and 2 In accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations, Public Service Company of Indiana, Inc. (PSI) of fers the following additional information as requested in your letter of May 15, 1980, concerning the item of noncompliance identified in Inspection Report No. 50-546/80-06, 50-547/80-06.

Item of Noncompliance (50-546/80-06-02; 50-547/80-06-02)

Marble Hill PSA.s, Chapter 17, Section 17.1.2 states that PSI will comply with the AEC Regulatory Guide, Guidance on Quality Assurance Requirements During the Construction Phase of Nuclear Power Plants, Revision 0 dated May 1974 (Green Book - Revision 0). The Green Book, Revision 0 endorses ANSI N45.2.5-1973, Draft 3, Revision 1 - January 1974.

The following requirements are specific areas in which conflicts between specification requirements and PSAR commitments were identified.

1. ANSI N45.2.5-1973, Table B requires that fresh concrete shall be sampled in accordance with ASTM C172. ASTM C172, Section 3.2.3 states that when concrete is sampled from revolving drum truck mixers or agitators, the sample shall be obtained from two or more regularly spaced intervals during discharge of the middle portion of the batch and that those samples shall be composited into one sample for test purposes.

Contrary to the above, Sargent & Lundy Specification Y-2850, Section 411.8Ab. states that, " Samples (concrete) shall be obtained in accordance with ASTM C172, except that when sauple is secured by diverting truck chute or pipe discharge into wheelbarrow, no compositing is required; and when central mixed concrete is delivered, sample may be taken from any portion of truck discharge."

JUNil 25ISEN) 8 008110436 P.O. Box 190, New Washington, Indiana 47162 812. 293.4441

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PUBUC SERVICE .

INDfANA June 16, 1980 Mr. G. Fiore11i 2. ANSI N45.2.5-1973, Table B requires cement to be sampled and tested every 500 bbis (94 tons) in accordance with ASTM C183 for in process chemical and physical testing as required by ASTM C150.

Contrary to the above , S&L Specification Y-2722, Section 403.3b states that cement sampling and testing, to ascertain conformance with ASTM C150, be performed at a frequency of every 1200 tons.

3. ANSI N45.2.5-1973, Table B endorses ASTM C31, " Making and Curing Concrete Test Specimens in the Field." Section 7.3 of ASTM C31 requires that compressive strength test specimens be removed f rom the molds at the end of 20 + 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and stored in a moist condition at 73.4 + 3 until the

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moment of test.

Contrary to the above , S&L Specification Y-2850, Section 411.7A states that " Molded cylinders may be left at the point of sampling for a maximum of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before being moved into moist curing in the laboratory . . ."

4. ANSI N45.2.5-1973, Table B requires that the design age compressive strength cylinders be cast from concrete samples obtained at the frequency of every 100 cubic yards.

Contrary to the above, Sargent & Lundy Specification Y-2722, Table 4-1-5 states that for "Other" Category I work, concrete samples shall be obtained every 150 cubic yards.

Corrective Action Taken and Results Achieved from April 22, 1980 letter

1. The purpose of the subsample compositing is to obtain a representative sample of the properties of a batch of concrete. Compositing subsamples of plastic concrete taken from a particular batch of fsets and makes less apparent any variations in air content, slump and temperature within that batch. The re fo re , the elimination of compositing places a greater burden on the production facility to maintain uniformity and as such is a conservative sampling practice.

Additionally, the degree of variation of properties within a batch of concrete is determined by separate periodic testing, such as, the sampling for uniformity tests performed in accordance with ASTM C94 as required in Specification Y-2850, Section 411.1. Since the specification method is more conservative than the ASTM C172 requirement , no change is required in Specification Y-2850.

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I PUBUC SERVICE INDIANA June 16, 1980 Mr. G. Fiore11i

2. In process chemical and physical testing as required by ASTM C150,

" Standard Specification for Hydraulic Cement" tests are performed by the cement supplier as stipulated in Specification Y-2722, Section 403.1, Section 403.2 of Specification Y-2722 also requires that the cement supplier furnish certification with each shipment (approximstely 24 tons) of cement that it meets the applicable chemical and physical requirements of ASTM C150.

This testing is separate from, and supplemental to the in-process testing squirements in ANSI N45.2.5-1973, Table B. Additionally, Section 403.3b, of Specification Y-2722 requires testing every 1200 tons and is in accordance with the ASME requirements necesrary to meet the testing requirements for cement testing in Section III, Division 2, " Concrete Reactor Vessels and Containments," Subparagraph CC-5221.2.

ANSI N45.2.5-1974 was changed to require ASTM C150 testing for every 1200 tons using ASTM C183 sampling method.

Based on ASME and later version of ANSI N45.2.5 - requirements, sampling and testing of cement at a frequency of every 1200 tons is adequate.

3. Seventy-two (72) hours time limit is specified in S&L Specification Y-2850, Section 411.7A to facilitiate construction practice. As per our pa s t experience 20 + 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time limit is adequate. Specification Y-2850 will be revised to delete Section 411.7A.

4. The reference documents used to establish required sampling frequencies tabulated in Specification Y-2722 and Y-2850, are published by the American Concrete Institute.

ACI 349, " Code Requirements for Safety-Related Concrete Structures,"

establishes a compressive scrength test frequency of one for every 150 cubic yards of concrete placed for Safety-Related structures other than the containment. This is the same requirement as in ACI 318, " Building Code Requirements for Reinforced Concrete".

In addition to the ninety-one (91) day cylinders, companion pairs of cylinders are tested at seven (7) days and twenty-eight (28) days for the purpose of monitoring early strength gain.

To comply with ANSI N45.2.5 requirements, S&L Specification Y-2722 will be revised to require compressive strength samples at a frequency of every 100 cubic yards.

PUBUC SERVICE

""*#"# June 16, 1980 Mr. G. Fiore11i Supplemental Corrective Action Taken and Results Achieved To provide consistency in the concrete testing program and to provide strict compliance to ANSI N45.2.5-1974, the applicable specifications have been amended cccordingly.

Co_rrective Action to Prevent Recurrence from April 22, 1980 letter

1. Since the specification method is more conservative than the ASTM C172 requirement, PSI believes it meets the intent of its commitment and no further action is required.

2. Based on ANSI N45.2.5-1974, PSI believes it meets the in:;nt of its commitment and r.o further action is required.

3. PSI will review applicable Specifications against Regulatory Guide 1.94, Revision 1, and endorsed standard ANSI N45.2.5-1974 to identify differences. The Specifications shall then be revised to incorporate any dif ferences which do not meet the intent of Regulatory Guide 1.94, Revision 1, and ANSI N45.2.5-1974.

4. The same as Item 3 above.

Supplemental Corrective Action to Prevent Recurrence PSI is performing a comprehensive review of the technical adequacy of test reports and supportive documenta 'on. This review, as described in special Process Procedure 13, shall include an engineering evaluation of the ef fect on past work where requirements may have not been fulfilled.

Date When Full Compliance will be Achieved from April 22, 1980 letter Specification revieus and revisions are planned to be completed with issuance of Engineering Change Notices by June 1, 1980.

Updated Date When Full Compliance will be Achieved Specification reviews and revisions were completed with issuance of Engineering Change Notice ECN S-166 on May 22, 1980. Scheduled completion date for supplemental review activities is August 1, 1980.

Sincerely, j' * /

S. W. Ehields TD/dks cc: J. J. Harrison E. R. Schweibinz, P.E.